In the 1972 case Gaffney v. Cummings, the Supreme Court of the United States addressed a challenge to Connecticut's state legislative redistricting plan. The plaintiffs argued that this plan violated their Fourteenth Amendment rights because it did not adhere strictly to "one person, one vote" principles due to slight population variances among districts. However, the court ruled in favor of Connecticut by a 6-3 margin. It held that minor deviations from mathematical equality among state legislative districts do not make out a prima facie case of discrimination under the Equal Protection Clause of Fourteenth Amendment as long as they are based on legitimate considerations incident to effectuation of rational state policy. In other words, small discrepancies in district populations were permissible if they served valid governmental purposes and didn't significantly dilute any group’s voting power.

In the dissenting opinion for Gaffney v. Cummings, Justice William O. Douglas argued that political gerrymandering is unconstitutional because it violates the Equal Protection Clause of the Fourteenth Amendment. He contended that any attempt to draw district lines based on partisan advantage undermines the principle of "one person, one vote," which requires that each individual's voting power be roughly equivalent to others'. According to him, this kind of redistricting strategy allows politicians in power to manipulate electoral boundaries and secure their own re-election or maintain party dominance - a practice he viewed as fundamentally undemocratic and discriminatory against voters from minority parties. Therefore, he believed courts should intervene in such cases and ensure fair representation by prohibiting politically motivated gerrymandering.