Baker v. Carr
Facts
Charles Baker (P) was a resident of Shelby County, Tennessee. Baker filed suit against Joe Carr, the Secretary of State of Tennessee. Baker’s complaint alleged that the Tennessee legislature had not redrawn its legislative districts since 1901, in violation of the Tennessee State Constitution which required redistricting according to the federal census every 10 years. Baker, who lived in an urban part of the state, asserted that the demographics of the state had changed shifting a greater proportion of the population to the cities, thereby diluting his vote in violation of the Equal Protection Clause of the Fourteenth Amendment.
Baker sought an injunction prohibiting further elections, and sought the remedy of reapportionment or at-large elections. The district court denied relief on the grounds that the issue of redistricting posed a political question and would therefore not be heard by the court.
Issues
1. Do federal courts have jurisdiction to hear a constitutional challenge to a legislative apportionment? 2. What is the test for resolving whether a case presents a political question?
Holding and Rule 1. Yes. Federal courts have jurisdiction to hear a constitutional challenge to a legislative apportionment. 2. The factors to be considered by the court in determining whether a case presents a political question are: 1. Is there a textually demonstrable constitutional commitment of the issue to a coordinate political department (i.e. foreign affairs or executive war powers)? 2. Is there a lack of judicially discoverable and manageable standards for resolving the issue? 3. The impossibility of deciding the issue without an initial policy determination of a kind clearly for non-judicial discretion. 4. The impossibility of a court’s undertaking independent resolution without expressing lack of the