In the case of Connor et al. v. Coleman, United States Circuit Judge, et al., 1975, the Supreme Court dealt with a dispute over redistricting in Mississippi following the 1970 census. The state legislature failed to enact a plan for reapportionment and so federal courts stepped in to create one instead. However, when an election was held under this court-ordered plan before it had been reviewed by either the Department of Justice or Supreme Court (as required by Section 5 of Voting Rights Act), several voters filed suit claiming that their constitutional rights were violated because they were not given equal representation due to malapportioned districts based on outdated population data from previous censuses. The Supreme Court ruled that while federal courts have authority to devise interim plans if state legislatures fail to do so after new census data is available, such plans must still comply with requirements set forth under Section 5 of Voting Rights Act before being implemented.

In the dissenting opinion for Connor et al. v. Coleman, United States Circuit Judge, et al., Justice William O. Douglas argued that the majority's decision to uphold Mississippi's newly redrawn legislative districts was a violation of the "one person, one vote" principle established in previous Supreme Court cases such as Reynolds v. Sims (1964). He contended that by allowing some districts to have significantly more residents than others - up to 16% variation in population size - the court was effectively sanctioning unequal representation and diluting individual voting power in more populous districts. Furthermore, he criticized his colleagues for failing to provide clear guidelines on what constitutes an acceptable level of population variance between different electoral constituencies and warned this could lead future courts into arbitrary decisions based on political considerations rather than constitutional principles.