In WMCA, Inc. v. Lomenzo (1963), the U.S Supreme Court ruled that New York's apportionment scheme violated the Equal Protection Clause of the Fourteenth Amendment because it was based on geographic considerations rather than population equality among districts. The case was brought by a group of voters and radio station WMCA, who argued that their votes were diluted due to malapportioned legislative districts in both houses of New York State Legislature. They claimed this system resulted in unequal representation for urban residents compared to rural ones, thus violating their constitutional rights under the Fourteenth Amendment’s equal protection clause. The court agreed with these arguments and held that all state legislative districts must be roughly equal in population size to ensure fair representation for all citizens.

In the dissenting opinion for WMCA, Inc. v. Lomenzo, Justice Harlan argued that the court should not have intervened in this case as it pertains to a political question rather than a judicial one. He believed that the issue of legislative apportionment was better suited for resolution by elected officials and voters, not judges who are unelected and unaccountable to citizens. Furthermore, he contended that there were no clear constitutional standards or principles available to guide courts in making such decisions about representation ratios between urban and rural areas within states. Therefore, he felt it was inappropriate for federal courts to interfere with state affairs on these matters without explicit guidance from either Congress or the Constitution itself.