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Smiley v. Holm, Secretary Of State

• 1931 • 285 U.S. 355 • Hughes Court
Smiley v. Holm was a U.S Supreme Court case in 1931 that dealt with the issue of redistricting and apportionment, specifically who has the power to draw congressional districts. The state of Minnesota had not redrawn its district lines following the 1920 census, resulting in an unequal distribution of population among its districts. Smiley sued Holm, Secretary of State for Minnesota, arguing that this violated Article I Section 2 Clause 3 (the Apportionment Clause) which requires states to...Open Case
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Chief Hughes Court
Term: 1931
Docket: 617
285 U.S. 355
52 S. Ct. 397
76 L. Ed. 795
1932 U.S. LEXIS 440
Argued: Mar 16, 1932

Smiley v. Holm, Secretary Of State

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Opinion Summary
AI Abstract

Smiley v. Holm was a U.S Supreme Court case in 1931 that dealt with the issue of redistricting and apportionment, specifically who has the power to draw congressional districts. The state of Minnesota had not redrawn its district lines following the 1920 census, resulting in an unequal distribution of population among its districts. Smiley sued Holm, Secretary of State for Minnesota, arguing that this violated Article I Section 2 Clause 3 (the Apportionment Clause) which requires states to reapportion their congressional seats after each federal census based on changes in population. The court ruled unanimously against Holm and held that redistricting is a legislative task subject to gubernatorial veto under Article I Section IV clause I (the Elections Clause). This means it's not solely up to one person or body within a state government but rather involves multiple branches working together through lawmaking processes. Therefore, if there are disagreements over how district lines should be drawn they must be resolved through political negotiation and compromise within each state’s legislature.

Dissent Summary
AI Abstract

In the dissenting opinion for Smiley v. Holm, it was argued that the court should not interfere in matters of state legislation regarding apportionment and redistricting unless there is a clear violation of constitutional rights. The dissenters believed that this case did not present such a violation, as Minnesota's legislature had acted within its powers to establish congressional districts according to population changes reflected in the census data. They contended that while the governor’s approval might be necessary for certain types of legislation under Minnesota law, it wasn’t required for all legislative acts including those related to redistricting which they considered procedural rather than substantive matter. Therefore, they disagreed with majority's view about necessity of gubernatorial participation in this process and held that Secretary Holm had rightly followed existing statute by implementing new district boundaries without waiting for additional legislative action or executive approval.

Opinion written by Justice CEHughes(2)
Decided: Apr 11, 1932
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