Mahan v. Howell

Date: February 15, 1973

Citation: 410 U.S. 315

Issue: Reapportionment

Significance: The Supreme Court relaxed mathematical equality standards for state legislative redistricting.

A Virginia state legislative redistricting plan was challenged because of deviations in district population that the state argued were the result of following county and city boundaries where possible. Justice William H. Rehnquist wrote the 5-3 majority decision for the Supreme Court maintaining that the one person, one vote standard in Reynolds v. Sims (1964) gave greater flexibility for deviations from exact mathematical equality in state legislative redistricting than in congressional redistricting. Mahan was one of four decisions in 1973 that allowed greater variances in state legislative than congressional redistricting cases, for which the mathematical exactness standard of Kirkpatrick v. Preisler (1969) continued to apply. Justices William J. Brennan, Jr., William O. Douglas, and Thurgood Marshall dissented.