Feb 19, 2025 Story by: Editor
Case Background
James P. Wesberry, a resident of a Georgia congressional district, argued that his district had a population two to three times larger than other districts in the state. Since each district had only one representative, he contended that his vote was effectively diluted due to Georgia’s apportionment statute and the state’s failure to redraw district boundaries. Wesberry sought to have the statute invalidated and requested a court order preventing the Governor and Secretary of State from holding elections under the existing district scheme. However, a lower court dismissed his complaint on the grounds of non-justiciability and lack of equity. Wesberry subsequently appealed the decision.
Key Legal Question
Did Georgia’s congressional district violate the Fourteenth Amendment or deny citizens the full value of their voting rights?
Supreme Court’s Decision
In a 6–3 ruling, the Supreme Court sided with Wesberry. Justice Hugo L. Black authored the majority opinion, with Justices William O. Douglas, Potter Stewart, William J. Brennan Jr., Byron R. White, and Chief Justice Earl Warren joining him in the decision.
The Court held that congressional districts should have roughly equal populations whenever feasible. It ruled that the lower court had jurisdiction over the case since vote dilution caused by state apportionment laws was a justiciable issue and should not have been dismissed for “want of equity.” Furthermore, the Court invalidated Georgia’s apportionment statute, stating that it violated Article 1, Section 2 of the U.S. Constitution, which mandates:
“The House of Representatives shall be composed of members chosen every second year by the people of the several states, and the electors in each state shall have the qualifications requisite for electors of the most numerous branch of the state legislature.”
Concurring and Dissenting Opinions
Justice Tom C. Clark concurred in part and dissenting in part. While he agreed that the lower court erred in dismissing the case, he argued that Article 1, Section 2 does not explicitly prohibit congressional districts from having disproportionate populations. He believed the case should have been sent back for further review to determine if the apportionment statute violated the Equal Protection Clause of the Fourteenth Amendment.
Justice John M. Harlan II dissented, asserting that the Constitution explicitly grants state legislatures and Congress exclusive authority over congressional apportionment matters.
Justice Stewart also dissented, aligning with Justice Harlan’s opinion but clarifying that his dissent should not be interpreted as implying that the case was non-justiciable. Source: Oyez
