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Baker v. Carr, (1962) was the first of a series of Supreme Court cases of the early 60s that established the federal judiciary's right to determine the constitutionality of legislative districting within a state (the allocation of state and federal representatives to voters).

Background

Charles Baker and a group of other voters brought legal action against the State of Tennessee in US District Court under (42 USC §§ 1983, 1986), Civil action for deprivation of rights. Their suit alleged that a 1901 state statute apportioned representatives of the Tennessee General Assembly arbitrarily and was in violation of the Tennessee Constitution. According to Baker et al., the formula being used under the 1901 law ignored economic and population growth centers, resulting in a situation where less populated voting districts were over-represented, while heavily populated districts were under represented.

Baker sought a judgment declaring the 1901 law unconstitutional and requested an injunction against the State enjoining it from conducting future elections under that law.

The federal District Court dismissed the case for lack of subject matter jurisdiction and declared no claim was stated for which the courts could grant relief. Further, the District Court believed redistricting to be a legislative, rather than judicial, matter.

Supreme Court

The question before the Supreme Court was not whether the Tennessee law was constitutional, but whether the District Court had acted properly in dismissing the case.

In a 6-2 opinion favoring Baker, the Court noted that, prior to 1901, the state had conducted a voter count by county, and distributed representation equally according to the number of voters in a given area. The Tennessee Constitution required the legislature follow a particular formula for apportionment of representatives, but the General Assembly ignored this mandate when they passed the 1901 statute.

Justice Brennan, who delivered the opinion of the Court, held that the District Court had jurisdiction over the case because Baker's claim rested on the Fourteenth Amendment Equal Protection Clause.

Further, the nature of the case was such that it could never be fairly resolved by legislature and required the intervention of the judiciary to ensure relief. The case was justicable.

The Court outlined a six-part test for determining which cases were political (matters for the legislature), rather than judicial (matters for the court).

Legislative Issues

  1. There exists a political entity with the power to address the situation.
  2. The court lacks a means of providing justice or a solution.
  3. The solution involves the creation of policy.
  4. The court would have to exercise powers constitutionally assigned to other branches.
  5. There is a requirement for adherence to an established political doctrine.
  6. More than one department could make concurrent but inconsistent decisions on the same question.

This test was later refined and rewritten in Reynolds v. Sims, 377 US 533 (1964), but served to delineate which cases could and could not be addressed by the judiciary. The Court also established the "one-man-one-vote" doctrine in Reynolds.

Decision of the District Court reversed, case remanded back to US District Court for adjudication.

Case Citation:

Baker v. Carr, 369 US 186 (1962)

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Tennessee Secretary of State Joe C. Carr was the nominal defendant in the case because his office was responsible for conducting elections, not because he or his office had been responsible for creating policy or voting districts. The Tennessee state legislature was being challenged, but Carr was sued ex officio in place of the state (which has sovereign immunity, per law).

Carr's position was simply that legislative apportionment and redistricting was a political question (a matter for the legislature), and didn't fall under the court's jurisdiction.

Case Citation:

Baker v. Carr, 369 US 186 (1962)

For more information on Baker v. Carr, see Related Questions, below.

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13y ago

The 1962 Supreme Court ruling held that reapportionment (local electoral districts being geographically altered) was "justiciable" therefore setting aside prior decisions supporting the legislatures argument that such matters were totally "Political questions" beyond the realm of Supreme Court action.

After this the Supreme Court has frequently made decisions either sustaining or overturning local reapportionment attempts.

Case Citation:

Baker v. Carr, 369 US 186 (1962)

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Baker won.

Baker v. Carr, (1962) was the first of a series of Supreme Court cases of the early 60s that established the federal judiciary's right to determine the constitutionality of legislative districting within a State (the allocation of state and federal representatives to voters).

Charles Baker and a group of other voters brought legal action against the State of Tennessee in US District Court under (42 USC §§ 1983, 1986), Civil action for deprivation of rights. Their suit alleged that a 1901 state statute apportioned representatives of the Tennessee General Assembly arbitrarily and was in violation of the Tennessee Constitution. According to Baker et al., the formula being used under the 1901 law ignored economic and population growth centers, resulting in a situation where less populated voting districts were over-represented, while heavily populated districts were under represented.

In a 6-2 opinion favoring Baker, the Court noted that, prior to 1901, the state had conducted a voter count by county, and distributed representation equally according to the number of voters in a given area. The Tennessee Constitution required the legislature follow a particular formula for apportionment of representatives, but the General Assembly ignored this mandate when they passed the 1901 statute.

Justice Brennan, who delivered the opinion of the Court, held that the District Court had jurisdiction over the case because Baker's claim rested on the Fourteenth Amendment Equal Protection Clause.

Case Citation:

Baker v. Carr, 369 US 186 (1962)

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13y ago

Baker v. Carr, (1962) was the first of a series of Supreme Court cases of the early 60s that established the federal judiciary's right to determine the constitutionality of legislative districting within a state (the allocation of state and federal representatives to voters).

Supreme Court

The question before the Supreme Court was not whether the Tennessee law was constitutional, but whether the District Court had acted properly in dismissing the case.

In a 6-2 opinion favoring Baker, the Court noted that, prior to 1901, the state had conducted a voter count by county, and distributed representation equally according to the number of voters in a given area. The Tennessee Constitution required the legislature follow a particular formula for apportionment of representatives, but the General Assembly ignored this mandate when they passed the 1901 statute.

Justice Brennan, who delivered the opinion of the Court, held that the District Court had jurisdiction over the case because Baker's claim rested on the Fourteenth Amendment Equal Protection Clause.

Further, the nature of the case was such that it could never be fairly resolved by legislature and required the intervention of the judiciary to ensure relief. The case was justicable.

The Court outlined a six-part test for determining which cases were political (matters for the legislature), rather than judicial (matters for the court).

Legislative Issues

  1. There exists a political entity with the power to address the situation.
  2. The court lacks a means of providing justice or a solution.
  3. The solution involves the creation of policy.
  4. The court would have to exercise powers constitutionally assigned to other branches.
  5. There is a requirement for adherence to an established political doctrine.
  6. More than one department could make concurrent but inconsistent decisions on the same question.

This test was later refined and rewritten in Reynolds v. Sims, 377 US 533 (1964), but served to delineate which cases could and could not be addressed by the judiciary. The Court also established the "one-man-one-vote" doctrine in Reynolds.

Decision of the District Court reversed, case remanded back to US District Court for adjudication.

Case Citation:

Baker v. Carr, 369 US 186 (1962)

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Chief Justice

Earl Warren

Associate Justices

Hugo Black

Felix Frankfurter (dissenting opinion, joined by Harlan)

William O. Douglas (concurring/plurality opinion joined by Clark and Stewart)

Tom C. Clark

John M. Harlan, II

William J. Brennan, Jr. (opinion of the Court/plurality joined by Warren and Black)

Potter Stewart

Charles E. Whittaker (did not participate)

Case Citation:

Baker v. Carr, 369 US 186 (1962)

For more information, see Related Questions, below.

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Q: In the US Supreme Court case Baker v. Carr what was Carr's claim?
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