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The 1960s: 1963
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Gray v. Sanders, March 18, 1963 (372 US 368)

Baker v. Carr (1962) is usually cited as the most important case in redistricting law, but the phrase "one man,one vote," which is so closely associated with the court's mandates on redistricting, actually came from the majority opinion in the lesser-known case of Gray v. Sanders. James O'Hear Sanders was an Atlanta businessman who challenged the constitutionality of Georgia's voting system as it affected both state and Congressional primaries. The Georgia federal court upheld the challenge and prompted the state, represented by Gray, to appeal to the Supreme Court. the Justices upheld the lower court's ruling. In his majority opinion, Supreme Court Justice William O. Douglas wrote: "The concept of political equality from the Declaration of Independence to Licoln's Gettysburg Address, to the 15th, 17th, and 19th Amendments can mean only one thing -- one man, one vote."

Gray v. Sanders dealt with inequities in the primaries and did not specifically address the questions of disproportionate districts, but the language of "one man, one vote" set the stage for a future focus on both legislative and congressional reapportionment.


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