Colegrove v. Green
Colegrove v. Green was a significant Supreme Court case addressing challenges to the congressional districting of Illinois. The plaintiffs, who were qualified voters, alleged that the state's congressional districts lacked compactness and equality, raising concerns about fair representation. The case was heard by a three-judge district panel, which dismissed the claims, a decision later affirmed by the Supreme Court in a closely contested 4-3 vote. Notably, the Court was operating with only seven justices at the time due to recent vacancies. Justice Felix Frankfurter, writing for the majority, contended that decisions regarding reapportionment were inherently political and best handled by state legislatures, with federal oversight as needed. This case highlighted the complexities and contentiousness surrounding electoral districting in the United States. The issue of reapportionment remained unresolved in the judicial system until it was revisited in Baker v. Carr in 1962, which set a new precedent by invoking the equal protection clause of the Fourteenth Amendment. As such, Colegrove v. Green serves as a pivotal moment in the ongoing dialogue about electoral fairness and legislative representation.
Colegrove v. Green
Date: June 10, 1946
Citation: 328 U.S. 549
Issue: Reapportionment
Significance: The Supreme Court declared reapportionment to be a political question and therefore not justiciable. This decision blocked all judicial efforts to correct malapportionment of legislative district boundaries until it was overturned in 1962.
Qualified Illinois voters challenged their state’s U.S. congressional districts, alleging a lack of compactness and equality. Following prevailing precedents, a three-judge district panel dismissed the case, and the Supreme Court affirmed the lower court’s decision by a 4-3 vote. Only seven justices participated in this case because Harlan Fiske Stone had died recently and Robert H. Jackson was at the Nuremberg trials. Justice Felix Frankfurter, in his majority opinion, argued that reapportionment was a political question best left to state legislatures under congressional oversight if necessary. Given the division within the Court, the issue was certain to be revisited, but it was sixteen years before the Court allowed the justiciability of reapportionment in Baker v. Carr (1962), justifying its decision with the Fourteenth Amendment’s equal protection clause.
