The Lucas v. Rhodes case in 1967 involved a dispute over the apportionment of Ohio's state legislature. The plaintiffs, Lucas and others, argued that the existing apportionment scheme violated their Fourteenth Amendment rights to equal protection because it resulted in unequal representation for urban voters compared to rural ones. They contended that each district should have roughly equal populations so that every person's vote would carry the same weight ("one person, one vote"). However, Governor James A. Rhodes and other defendants maintained that this was not necessary under Ohio law or the U.S Constitution. The Supreme Court ruled in favor of Lucas et al., finding indeed an unconstitutional imbalance existed due to population disparities among districts which diluted urban votes' value relative to those from less populated areas. This ruling reinforced previous decisions emphasizing "one person, one vote" principle as fundamental for fair representation within democratic systems.

In the dissenting opinion for Lucas et al. v. Rhodes, Governor of Ohio, et al., Justice Harlan argued that the court's decision to intervene in state legislative apportionment was a departure from established constitutional principles and an overreach of judicial power. He contended that such matters should be left to the political process and not decided by courts. The justice believed that there were no clear standards or guidelines provided by the Constitution on how states should apportion their legislatures; thus, it was inappropriate for federal courts to impose their own views on this issue. Furthermore, he expressed concern about potential consequences of this ruling - including increased litigation and further politicization of judiciary - which could undermine public confidence in both institutions.