Baker v. Carr (1962) is the U.S. Supreme Court case that held that federal courts could hear cases alleging that a state’s drawing of electoral boundaries, i.e. redistricting, violates the Equal Protection Clause of the Fourteenth Amendment of the Constitution. In so ruling, the Court also reformulated the political question doctrine. Find the full text of the case here.
In the case, the plaintiff lived in an urban Tennessee voting district which was relatively underrepresented compared to rural voting districts. Tennessee law required districts to be redrawn every ten years, but Tennessee had not done so in decades. The plaintiff sued in federal district court, claiming that the law required Tennessee to redraw their districts to make each district’s representation substantially equal to its population. The lower court held it was a political question and therefore non-justiciable, dismissing plaintiff’s case. The U.S. Supreme Court disagreed and held that the constitutionality of a legislative appointment scheme was not a political question and therefore was justiciable; i.e., a federal court could hear the case and decide on the merits.
In finding this case justiciable, the Court created the political question doctrine, which creates a series of factors, at least one of which must be present, in order for the case to be a non-justiciable political question. Under the doctrine, if any of the following are met, then the court may not hear the case: (a) commitment of the issue to a branch of government other than the judiciary; (b) lack of standards for resolving the issue; (c) impossibility of the judiciary to resolve the issue without first making a policy determination; (d) a judicial decision of that matter as a lack of respect for other branches of government; (e) a political decision has already been made; or (f) the potential for multiple pronouncements by various branches on one question.
Further, by holding that such cases were justiciable, the Supreme Court paved the way for federal courts to hear and decide on claims that electoral districts violated the equal protection clause. Two years later, the U.S. Supreme Court relied on Baker to require that the United States House of Representatives and state legislatures establish electoral districts of equal population in Wesberry v. Sanders and Reynolds v. Sims. Future cases also invoked Baker’s formulation of the political question doctrine, such as Nixon v. United States.
[Last updated in December of 2021 by the Wex Definitions Team]
Resources
Full text of Baker v. Carr (1962)
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