In the 1988 case, Board of Estimate of City of New York v. Morris et al., the U.S. Supreme Court ruled that New York City's government structure violated the "one person, one vote" principle established in previous cases interpreting the Equal Protection Clause of the Fourteenth Amendment. The city's Board of Estimate was comprised of eight officials: five borough presidents (each representing a different borough) and three citywide elected officials (the mayor, comptroller and council president). Each member had one vote on matters such as budgeting and land use despite vast differences in population size among their constituencies. This meant that residents from less populous boroughs were overrepresented compared to those from more populous ones. The court held this system unconstitutional because it diluted votes based on where citizens lived within NYC, violating equal protection principles.

In the dissenting opinion for Board of Estimate of City of New York v. Morris, Justice Stevens argued that the court's majority decision was a misinterpretation and overextension of the "one person, one vote" principle from earlier cases. He contended that this principle should not be applied to every governmental body but only those with general legislative powers. The Board in question had unique characteristics and its members were elected by different constituencies; it did not have broad legislative authority but rather performed specific functions related to city budget and land use decisions. Therefore, he believed it was inappropriate to apply strict population-based representation rules as if it were a typical legislature. Furthermore, he expressed concern about potential negative impacts on local government structures across the country due to this ruling.