Introduction

Sue Evenwel, et al., Appellants v. Greg Abbott, Governor of Texas, et al. (578 U.S. 54) is a pivotal case adjudicated by the Supreme Court of the United States on April 4, 2016. The appellants, Texas voters, challenged the state's method of drawing legislative districts based on total population rather than voter-eligible population. They contended that this approach resulted in unequal representation, effectively diluting their votes in comparison to other districts. The defendants, including Governor Greg Abbott, maintained that utilizing total population is both constitutionally permissible and consistent with established legal principles.

Summary of the Judgment

The Supreme Court affirmed the decision of the United States District Court for the Western District of Texas, ruling in favor of the appellees. The Court held that Texas's method of apportioning legislative districts based on total population does not violate the One-Person, One-Vote principle under the Equal Protection Clause of the Fourteenth Amendment. The justices concluded that historical context, constitutional provisions, and longstanding judicial precedent support the legitimacy of total population-based districting.

Justice Ginsburg delivered the opinion of the Court, emphasizing that the Equal Protection Clause permits states to employ any neutral and nondiscriminatory population baseline, including total population. The majority opinion also addressed and rejected arguments advocating for voter-eligible population bases, upholding the conventional practice and legal standards surrounding legislative districting.

Analysis

Precedents Cited

The Court extensively referenced landmark cases that have shaped the One-Person, One-Vote doctrine:

• BAKER v. CARR (1962): Established the justiciability of malapportionment claims under the Equal Protection Clause.
• WESBERRY v. SANDERS (1964): Mandated equal population in congressional districts.
• REYNOLDS v. SIMS (1964): Extended equal population requirements to state legislative districts.
• AVERY v. MIDLAND COUNTY (1968): Applied the One-Person, One-Vote rule to local level legislative reapportionment.
• CHAPMAN v. MEIER (1975): Defined maximum permissible population deviations in districting.

These precedents collectively underscore the judiciary's role in ensuring equitable representation, primarily through the lens of total population metrics.

Legal Reasoning

The Court's reasoning hinged on constitutional history and interpretative consistency. It noted that from the Constitution's inception, representation in the House of Representatives was based on total population, a principle rooted in the Great Compromise of 1787. This historical foundation was further solidified by the Fourteenth Amendment, which reinforced population-based apportionment to ensure fair representation across states.

The majority argued that deviations from perfect population equality are permissible to accommodate traditional districting objectives such as maintaining political subdivisions, preserving communities of interest, and ensuring geographic compactness. They highlighted that only deviations exceeding a 10% maximum population deviation are presumptively impermissible.

Additionally, the Court dismissed the appellants' claims that the Constitution necessitates voter-eligible population-based apportionment. It emphasized that the Equal Protection Clause supports apportionment based on any neutral, nondiscriminatory population measure, including total population.

Impact

This judgment has significant implications for future legislative districting processes:

• Reaffirmation of Total Population-Based Districting: States are constitutionally permitted to use total population metrics for legislative apportionment, not mandating voter-eligible populations.
• Judicial Clarification: The decision clarifies that while the One-Person, One-Vote principle aims for equal representation, it does not prescribe the specific population metric to be used.
• Stability in Districting Practices: By upholding established practices, the Court ensures consistency and predictability in how states design their legislative districts.
• Reduced Federal Oversight: States retain significant autonomy in determining the criteria for districting, limiting federal judicial intervention unless clear constitutional violations are evident.

The ruling thus balances the principles of equal representation with the practical considerations states must navigate in districting, preserving state sovereignty over internal governance matters.

Complex Concepts Simplified

One-Person, One-Vote Principle

This principle mandates that each individual's vote should carry equal weight in legislative elections. It seeks to ensure that legislative districts are apportioned fairly, preventing scenarios where some voters have more influence than others based on their district's population.

Equal Protection Clause

Found in the Fourteenth Amendment, this clause prohibits states from denying any person within their jurisdiction the equal protection of the laws. In the context of this case, it ensures that legislative districting does not result in unequal representation that dilutes individual votes.

Malapportionment

Malapportionment refers to the creation of legislative districts with significantly unequal populations, which can lead to unequal representation and voting power among citizens.

Maximum Population Deviation

This term refers to the allowable variance in population between the largest and smallest legislative districts. The Court has generally held that a maximum deviation below 10% is presumptively acceptable, while deviations exceeding 10% are likely unconstitutional.

Conclusion

The Supreme Court's decision in Sue Evenwel v. Abbott solidifies the constitutionality of total population-based legislative districting in Texas, affirming that such practices align with the One-Person, One-Vote principle under the Equal Protection Clause. By analyzing constitutional history, precedent, and practical districting considerations, the Court upheld the legitimacy of states using total population metrics for apportionment. This judgment reinforces the balance between ensuring equitable representation and respecting states' autonomy in legislative districting, setting a clear standard for future cases and legislative practices nationwide.