The Rockefeller v. Wells case in 1967 was a dispute over the constitutionality of New York's apportionment plan for state senate districts. The plaintiffs, including George W. Wells, argued that the plan violated the Equal Protection Clause of the Fourteenth Amendment because it gave disproportionate representation to rural areas at the expense of urban ones. They contended that this resulted in "invidious discrimination" against voters in more populous counties. However, Governor Nelson A. Rockefeller and other defendants maintained that their system was based on traditional principles such as maintaining county integrity and giving due recognition to geographic factors and political subdivisions. In its decision, the Supreme Court upheld New York's apportionment scheme by a vote of 5-4, ruling that it did not violate equal protection requirements under federal law or Constitution’s Fourteenth Amendment since population is not always decisive factor when considering fair representation within states' legislative bodies.

In the case of Rockefeller, Governor of New York, et al. v. Wells et al., Justice Douglas dissented from the majority opinion. He argued that while states have a right to manage their own affairs and structure their governments as they see fit, this does not extend to violating fundamental principles of representative government enshrined in the Constitution - namely equal protection under law and one person-one vote principle. He contended that disparities in population between districts resulted in unequal representation for citizens depending on where they lived; some voters had more influence than others simply because of geography which was fundamentally unfair and undemocratic according to him. Furthermore, he criticized the court's decision for allowing political considerations such as maintaining existing boundaries or preserving incumbent advantages to justify these inequalities rather than insisting on strict adherence to constitutional principles.