In the case of Forty-Fourth General Assembly of Colorado et al. v. Lucas et al., 1964, the U.S Supreme Court ruled on a dispute regarding electoral districting in Colorado. The plaintiffs argued that the state's reapportionment plan violated their Fourteenth Amendment rights to equal protection under law as it resulted in unequal representation due to population disparities among districts. The defendants, members of the state assembly, contended that factors other than population should be considered when drawing district lines and maintaining rural influence was important for balanced governance. The court sided with Lucas and others by a vote of 8-1, ruling that both houses of bicameral state legislatures must have districts roughly equal in population size according to "one person one vote" principle established earlier in Reynolds v Sims (1964). This decision invalidated Colorado’s apportionment scheme which gave disproportionate weightage to rural areas over urban ones despite significant differences in populations between them.

In the dissenting opinion for the case of Forty-Fourth General Assembly of Colorado v. Lucas, Justice Harlan argued that the court majority had overstepped its authority by intervening in a matter he believed should be left to state discretion. He contended that there was no constitutional violation in this case and thus, it did not warrant federal judicial intervention. According to him, reapportionment issues were political questions best resolved through legislative processes rather than judicial ones. Furthermore, he expressed concern about potential negative consequences resulting from such interventions on local democratic institutions and practices. His view was rooted in his belief in states' rights and limited federal interference.