Baker v. Carr
369 U.S. 186 (1962)
Constitutional Topic Areas:
14th Amendment ‘Equal Protection Clause’, Article III, Judicial Review, Appellate Jurisdiction, Apportionment
Case Facts:
Charles Baker was a Tennessee Resident and Mayor of Millington, TN who filed suit in federal court against then Tennessee Secretary of State Joe Carr. Baker argued his 14th Amendment Equal Protection rights were violated because Tennessee reapportionment had not been concluded in over 60 years– the Tennessee State Constitution mandated this be done every 10 years. As a result of population migration from rural districts to the cities, rural districts had more voting power/influence by population. The State Court dismissed Baker’s suit, claiming the case was a political question, therefore was non-justiciable. This was ultimately based on the Supreme Court’s precedent ruling on Colegrove v. Green (1946). Baker appealed to the US Supreme Court.
Questions:
1. Does an equal protection challenge to apportionment qualify as a political question?
2. Is Baker’s case justiciable?
Holding:
1. No
2. Yes
Legal Reasoning: Justice W.J. Brennan (6-2)
1. The plaintiffs rights to have their vote counted equally and fairly gave legal interest to the suit
2. The suit did not constitute as a political question, thus overturning Colegrove v. Green
3. A court could determine the constitutionality of a State’s apportionment without interfering with the State’s political judgement
Concurrence: Justice P. Stewart
1. The Court only decided that:
A) That the District Court possessed jurisdiction over the subject matter
B) that the complaint presents a justiciable controversy
3) The appellants have standing
Dissent: Justice F. Frankfurter
1. “Appellants invoke the right to vote and to have their votes counted. But they are permitted to vote and their votes are counted. They go to the polls, they cast their ballots, they send their representatives to the state councils. Their complaint is simply that the representatives are not sufficiently numerous or powerful”
Significance:
Baker opened the door to a multitude of apportionment cases over the years. One year following the decision of this case, the principle of “one man one vote” was established based on Baker during Reynolds v. Sims (1964). Furthermore, in Westbury v. Sanders (1964), this principle was extended to “one man’s vote in federal, congressional elections, is to be worth as much as another’s”
Reflection:
Baker’s 6-2 vote isn’t as strong as a unanimous vote, but still solidifies it’s precedent and unlikeliness to be overturned in the future. Baker continues to be relevant today, as complex cases of legislative district design continue to be adjudicated. Cases such as Hunt v. Cromartie (1999) highlight Baker as a strong precedent, as districts drawn unfairly, in this case to group African Americans into one district, are unconstitutional by violation of the 14th Amendment’s Equal Protection Clause. Overall, Baker strengthened the power of the federal government
Supreme Court Case Briefs 