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The 1960s: 1964
Court Cases

Wesberry v. Sanders, February 1964

The Georgia court case of Wesberry v. Sanders significantly expanded the concept of "one man, one vote" and is most often linked with the phrase. The court's ruling on Wesberry v. Sanders explicitly stated that Congressional districts must be as equal in population as is practical. In the decision there was still no mention of the role of state legislative bodies, but the justices seemed to be headed toward guidelines that would determine how state legislative boundaries were drawn.




Reynolds v. Sims, June 15, 1964 (277 US 533)

The Supreme Court handed down six decisions on June 15, 1964 and collectively they have come to be known by the name of one of these cases, Reynolds v. Sims, which originated in Alabama. The ruling in Reynolds v. Sims addressed four major issues that affected legislative reapportionment:

  1. both houses of a state legislature must be equally apportioned according to population;
  2. equal apportionment of legislative districts must be based as much as possible on population figures, although mathematical exactness might be impossible;
  3. the historic circumstances that gave rise to the federal system of apportionment in Congress is not applicable to state legislatures, and
  4. apportionment that fails to meet the preceding guidelines—even if approved by a majority of the state's citizens—is unconstitutional because "constitutional rights can hardly be infringed on because a majority of the people choose to do so."

The message of Reynolds v. Sims was clear: the states must apportion legislative districts to contain equal populations and allow each citizen's vote to have equal weight.




Thigpen v. Meyers, June 22, 1964 (211 FS 826)

In December 1962, the United States District Court for the Western District of Washington heard the case of Thigpen v. Meyers. James Thigpen, a Justice of the Peace from a small town south of Seattle, initiated the lawsuit and argued that his right to "equal protection" was violated by the huge imbalances in the size of the state's legislative districts. The State of Washington, represented by Secretary of State Victor Meyers, claimed that there were "insufficient facts of which the Court may take judicial notice, and inasmuch as the Court may not consider other evidence, it is unable to adjudicate the issues involved." The ruling in Baker v. Carr had clearly put redistricting within the scope of the judicial powers, and the District Court used this power to declare Washington's legislative districts null and void. In his opinion, Justice William Beeks wrote that the population variance rendered the districts "invidiously discriminatory."

The State appealed the case to the Supreme Court, but in June 1964 the Court upheld the lower court's ruling in Thigpen v. Meyers on the same day it addressed several other reapportionment cases from around the country. The failure of the appeal in Thigpen v. Meyers forced the Washington Legislature to redistrict during the 1965 session and other state legislatures had to follow suit. The case of Thigpen v. Meyers was specific to Washington State, but by 1964 it was clear that this and other court rulings in the early 1960s had profoundly affected voting rights in the nation as a whole.

View the legislative district map from Thigpen v. Meyers »


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