Term: 2015
Docket: 14-940
Evenwel v. Abbott
- Pro
14-940 EVENWEL V. ABBOTT DECISION BELOW: 2014 WL 5780507 JURISDICTION NOTED 5/26/2015 QUESTION PRESENTED: In Reynolds v. Sims, 377 U.S. 533 (1964), this Court held that the Equal Protection Clause of the Fourteenth Amendment includes a "one-person, one-vote" principle. This principle requires that, "when members of an elected body are chosen from separate districts, each district must be established on a basis that will insure, as far as is practicable, that equal numbers of voters can vote for proportionally equal numbers of officials." Hadley v. Junior Coll. Dist. Of Metro. Kansas City, Mo., 397 U.S. 50, 56 (1970). In 2013, the Texas Legislature enacted a State Senate map creating districts that, while roughly equal in terms of total population, grossly malapportioned voters. Appellants, who live in Senate districts significantly overpopulated with voters, brought a one-person, one--vote challenge, which the three-judge district court below dismissed for failure to state a claim. The district court held that Appellants' constitutional challenge is a judicially unreviewable political question. The question presented is whether the "one-person, one-vote" principle of the Fourteenth Amendment creates a judicially enforceable right ensuring that the districting process does not deny voters an equal vote. LOWER COURT CASE NUMBER: 1:14-cv-335
The U.S. Supreme Court case Evenwel v. Abbott in 2015 dealt with the issue of "one person, one vote" and how states could constitutionally draw their legislative districts. The plaintiffs, Sue Evenwel and Edward Pfenninger from Texas, argued that counting total population instead of eligible voters diluted their votes in violation of the Equal Protection Clause under the Fourteenth Amendment. They contended that districts should be drawn based on voter-eligible population to ensure equal representation for voters rather than total residents. However, the court unanimously ruled against them stating that a state can use total population when drawing legislative districts as it provides equality in representation among all constituents regardless of voting eligibility status.
In the case of Evenwel v. Abbott, Justice Clarence Thomas issued a dissenting opinion. He argued that the Constitution does not prescribe any particular method for apportionment and thus states have significant leeway in choosing their own methods. He criticized the majority's reliance on historical practices to justify equalizing total population instead of eligible voters, stating that history did not support such an interpretation. Furthermore, he contended that using total population as a basis could lead to districts with vastly different numbers of eligible voters, thereby diluting some citizens' votes contrary to principles of representative democracy. In his view, states should be allowed to use either total population or voter-eligible populations when redistricting if they choose.
