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====Reapportionment (one man, one vote)==== {{quote box | quote = The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise.| source = --[[Chief Justice of the United States|Chief Justice]] Earl Warren on [[Suffrage|the right to vote]] as the foundation of [[democracy]] in ''[[Reynolds v. Sims]]'' (1964).<ref>{{cite web |title=''Reynolds v. Sims'', 377 U.S. 533 (1964), at 555. |url=https://supreme.justia.com/cases/federal/us/377/533/ |publisher=Justia US Supreme Court Center |access-date=January 5, 2021 |date=June 15, 1964}}</ref> | width = 27% | align = right | style = padding:8px; }} In 1959, several residents dissatisfied with Tennessee's legislative districts brought suit against the state in ''[[Baker v. Carr]]''. Like many other states, Tennessee had state legislative districts of unequal populations,{{efn|The [[Vermont General Assembly]] provides one example of the disparity in populations. In 1961, one member of the Vermont General Assembly represented 33,000 people, and another member represented 49 people.{{Sfn|Cray|1997|p=380}}}} and the plaintiffs sought more equitable legislative districts. In ''[[Colegrove v. Green]]'' (1946), the Supreme Court had declined to become involved in legislative apportionment and instead left the issue as a matter for Congress and the states. In ''[[Gomillion v. Lightfoot]]'' (1960), the Court struck down a redistricting plan designed to disenfranchise African-American voters, but many of the justices were reluctant to involve themselves further in redistricting.{{Sfn|Cray|1997|pp=379β381}} Frankfurter insisted that the Court should avoid the "political thicket" of apportionment and warned that the Court would never be able to find a clear formula to guide lower courts.<ref>{{cite journal|first=James A.|last=Gazell|title=One Man, One Vote: Its Long Germination|journal=[[The Western Political Quarterly]]|volume=23|issue=3|date=September 1970|pages=445β462|jstor=446565|doi=10.1177/106591297002300301|s2cid=154022059}}</ref> Warren helped convince Associate Justice [[Potter Stewart]] to join Brennan's majority decision in ''Baker v. Carr'', which held that redistricting was not a [[political question]] and so federal courts had jurisdiction over the issue. The opinion did not directly require Tennessee to implement redistricting but instead left it to a federal district court to determine whether Tennessee's districts violated the Constitution.{{Sfn|Cray|1997|pp=381β385}} In another case, ''[[Gray v. Sanders]]'', the Court struck down Georgia's [[County Unit System]], which granted disproportional power to rural counties in party primaries.{{Sfn|Cray|1997|pp=406β407}} In a third case, ''[[Wesberry v. Sanders]]'', the Court required states to draw congressional districts of equal population.{{Sfn|Cray|1997|p=433}} In ''[[Reynolds v. Sims]]'' (1963), the chief justice wrote what biographer Ed Cray terms "the most influential of the 170 majority opinions [Warren] would write." While eight of the nine justices had voted to require congressional districts of equal population in ''Wesberry'', some of the justices were reluctant to require state legislative districts to be of equal population. Warren indicated that the [[Equal Protection Clause]] required that state legislative districts be apportioned on an equal basis: "legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests." His holding upheld the principle of "[[one man, one vote]]," which had previously been articulated by Douglas.{{Sfn|Cray|1997|pp=432β435}} After the decision, the states reapportioned their legislatures quickly and with minimal troubles. Numerous commentators have concluded reapportionment was the Warren Court's great "success story."<ref>{{cite journal|first=Robert B.|last=McKay|title=Reapportionment: Success Story of the Warren Court|journal=[[Michigan Law Review|Mich. L. Rev.]]|volume=67|issue=2|date=December 1968|pages=223β236|jstor=1287416|doi=10.2307/1287416|url=https://repository.law.umich.edu/cgi/viewcontent.cgi?article=4900&context=mlr}}</ref>
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