Evenwel v. Abbott Case Brief

Facts of the Case

Under the one-person, one-vote principle, jurisdictions must design legislative districts with equal populations. In the context of state and local legislative districting, States may deviate somewhat from perfect population equality to accommodate traditional districting objectives. Where the maximum population deviation between the largest and smallest district is less than 10%, a state or local legislative map presumptively complies with the one-person, one-vote rule.

Question

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CONCLUSION

“The “one person, one vote” principle of the Equal Protection Clause allows a state to design its legislative districts based on total population. Justice Ruth Bader Ginsburg delivered the unanimous decision and the opinion for the six-justice majority. The Court held that constitutional history, judicial precedent, and consistent state practice all demonstrate that apportioning legislative districts based on total population is permissible under the Equal Protection Clause. Based on the wording of the Fourteenth Amendment and the legislative debates surrounding its adoption, the legislature at the time clearly intended for representation to be apportioned in the House based on total population, and it would be illogical to prohibit the states from doing the same within their own legislatures. In cases in which the Court has evaluated whether districting maps violate the Equal Protection Clause, the Court has consistently looked at total population figures to determine whether the maps impermissibly deviate from perfect population equality. Additionally, the total population approach has been used by all states and many local jurisdictions, and there is no reason to upset this accepted practice.In his opinion concurring in the judgment, Justice Clarence Thomas wrote that the Court’s Equal Protection Clause jurisprudence has not established a single theory for how states should uphold the “one person, one vote” principle. Similarly, Justice Thomas argued that the Constitution does not prescribe a theory for states to use when apportioning representation. Although there is some preference for majoritarian rule, the Constitution also reflects concern about the tyranny of the majority by including counter-democratic checks. Given these conflicting theories present in the Constitution and the fact that the Constitution lets the states determine their own methods of apportioning representation, the Court should not impose a singular theory on the states. Because the total population method is a permissible method for states to use in creating legislative districts, Justice Thomas agreed with the majority, but noted that this was not the only permissible method. Justice Samuel A. Alito, Jr. wrote a separate opinion concurring in the judgment in which he argued that neither the text nor the legislative history of constitutional apportionment for legislative districts endorses one theory over another. Therefore, while the total population theory is permissible, it is not the only one. Justice Thomas joined in the concurrence in the judgment.”

Case Information

Citation: 578 US (2016)
Granted: May 26, 2015
Argued: Dec 8, 2015
Decided: Apr 4, 2016
Case Brief: 2016