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Karcher v. Daggett, 462 U.S. 725, 103 S.Ct. 2653, 77 L.Ed.2d 133

Facts

After the 1980 census, New Jersey's congressional districts were reapportioned, resulting in 14 districts with an average population of 526,059. The largest district had a population of 527,472, while the smallest had 523,798, leading to a maximum deviation of 0.6984%. A group of individuals challenged the validity of the reapportionment plan, arguing it violated Article I, § 2 of the Constitution due to the population variances not being the result of a good-faith effort to achieve equality. The district court held a hearing and ultimately declared the plan unconstitutional.

As a result of the 1980 census, the New Jersey Legislature reapportioned the State's congressional districts. The reapportionment plan contained 14 districts, with an average population per district of 526,059, each district, on the average, differing from the 'ideal' figure by 0.1384%.

Issue

Whether New Jersey's congressional reapportionment plan satisfies Article I, § 2 of the Constitution without further justification if the population of the largest district is less than one percent greater than the population of the smallest district.

The question presented by this appeal is whether an apportionment plan for congressional districts satisfies Art. I, § 2 without need for further justification if the population of the largest district is less than one percent greater than the population of the smallest district.

Rule

The 'equal representation' standard of Article I, § 2 requires that congressional districts be apportioned to achieve population equality as nearly as practicable. Parties challenging apportionment legislation bear the burden of proving that population differences could have been reduced or eliminated by a good-faith effort to draw districts of equal population.

1. The 'equal representation' standard of Art. I, § 2, requires that congressional districts be apportioned to achieve population equality as nearly as is practicable.

Analysis

The court applied the rule by determining that the population deviations in New Jersey's plan were not justified by a good-faith effort to achieve equality. The court found that the state did not meet its burden of proving that the population deviations were necessary for a legitimate goal, as the primary justification of preserving minority voting strength was not substantiated with evidence linking the specific population disparities to that goal.

The District Court properly found that the defendants did not meet their burden of proving that the population deviations in the plan were necessary to achieve a consistent, nondiscriminatory legislative policy.

Conclusion

The Supreme Court affirmed the district court's ruling, concluding that the New Jersey reapportionment plan was unconstitutional due to the lack of a good-faith effort to achieve population equality and insufficient justification for the population deviations.

Held: 1. The 'equal representation' standard of Art. I, § 2, requires that congressional districts be apportioned to achieve population equality as nearly as is practicable.

Who won?

The plaintiffs prevailed in the case as the court found that the state failed to justify the population deviations in the reapportionment plan.

The District Court held that the plan violated Art. I, § 2, of the Constitution because the population deviations among districts, although small, were not the result of a good-faith effort to achieve population equality.

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