Supreme Court of the United States
Baker v. Carr
v. Carr : 369 U.S. 186, 82 S. Ct. 691 7 L. Ed. 2d 663 (1962)
Appellants – Charles Baker, Republican
resident from Tennessee; Mayor of Millington, Tennessee v. Joe Carr; Secretary of State for
Argued – April 18-19, 1961
Reargued – Oct 9, 1961
Decided – March 26, 1962
This case was presented in a Federal
District court in Tennessee on behalf of Mayor Charles Baker and citizens of
Tennessee, filing a complaint stating that their Fourteenth Amendment rights
were being violated. Charles Baker and
other residents from Tennessee state that Tennessee had not been redistricted
since 1901. The Tennessee Constitution required revising districts to redraw
seats for the state’s General Assembly every ten years to redress any changes
in population, and had been ignored since then. Baker argued that votes of other
rural citizens were overrepresented compared to demographically shift that had
occurred in his district within the years. Baker complained that due to failure
to reapportioning the seats in the General Assembly, apart from the disparity of
population of his district and substantial growth, they lacked “debasement
of their votes” and caused him to lack equal protection under the
Fourteenth Amendment. Charles Baker filed a lawsuit against Secretary of State,
Joe Carr due to carrying out elections and district maps.
sets district lines
case because they alleged that courts could not resolved this matter due to
being a “political issue.”
debate of this case was if the Supreme Court has jurisdiction of legislative apportionment
The District court did have official power to rule over such case declared in
2. Appellants had sufficient proof to support their allegations.
Pp. 369 U.S, 204 -208.
3. Baker’s allegation of a rejection of equal protection was a justifiable constitutional
matter, therefore was entitled to a trail and decision. Pp. 369 U.S. 208-37.
179 F.Supp. 824, case was reversed and remanded
The decision of this case was six to
two, and was finalized March 1962 by a plurality of votes because no majority
came forward from either side. Justice
Charles Evans Witttakers even withdrew from case for the sake of his health
conditions. There were two concurrences
by Justices William Douglas and Potter Stewart.
Justice William Brennan did
agree that this was a justiciable issue rather than a political, but since
there was no majority, Court remanded the case to the lower courts.
Justice Felix Frankfurter however, stated the Court did go further beyond their
judicial roles and should have permitted the political process handle the
situation. Frankfurter states that legal intervention was pointless in an
essentially political conflict . Practice had been cast aside and Court had
violated the separation of powers between the Courts and legislative. He
addresses how the Court should detach from any political entanglement. No
judicial remedy had been established under the Constitution and not every
political mischief should have a remedy through the Court. Justice Harlan who joined dissenting with
Justice FrankFurter, argued that nowhere in the Equal Protection Clause or in
the Federal Constitution particularly supported that state legislature must be so structured
and fairly accurate in regards to the equality voice of every voter. He expressed
that Baker should had seek alleviation from the legislative and how other cases
similar had been rejected.
While Justice Harlem and Justice
Frankfurter oppose to this suit, Justice William Brennan stated that Courts did
have the power to consider and decide the case after properly addressing the
case to determine what amounts to a political question.
The majority opinion did came
to a conclusion that even with constrains, judiciary can rule over
apportionment decisions, however, the court couldn’t decide to any liberation
granted to Baker therefore the Court sent case back to lower courts to rehear
Apportionment cases had been based
under the Guaranty Clause of Article IV, Section: 4 of the United States Constitution
which states that each State is guaranteed a republican form of government and
that such matter that presents a political question shall not be addressed by
the courts. In this case, the Guaranty Clause was rejected due to the fact that
the Appellants argued the apportionment of legislatures under the Equal
an outcome of this case, the Supreme Court established the power that the
Supreme court can review any legislative and redistricting matters.
The decision in this case and the
court’s explanation of the political question doctrine has strongly affected
constitutional law and voting rights over the past decades.
Although this case took nearly a
year to finalized because appellant requested political rights, did not mean
however it a “political” issue. This case argued that any
apportionment case, should have not involve any federal court. The
“political question” doctrine came into consideration concerning if the judicial systems is the best
suitable system to perceive over such
case. This doctrine deals with any
measures and powers that have been committed
to another branch of government. As many cases similar to Baker v. Carr,
this case gave power to the court to protect voting rights under the 14th
amendment. It also demanded that every state shall undergo a redistricting to
protect the right of each voter. Because of this case, Supreme court made ascertained
that these types of cases of reapportionment are in fact a case that should be
reviewed by the court.