Mahan v. Howell
Mahan v. Howell refers to a significant Supreme Court case concerning legislative redistricting in Virginia. The case revolved around a challenge to the state's redistricting plan, which had variations in district populations. The state justified these discrepancies by citing the need to adhere to existing county and city boundaries. In a 5-3 majority decision led by Justice William H. Rehnquist, the Court concluded that the "one person, one vote" principle established in Reynolds v. Sims allowed for more flexibility regarding population deviations in state legislative redistricting compared to congressional redistricting. This case was part of a broader trend in 1973, where the Court upheld greater variances in state legislative districts while maintaining stricter standards for congressional districts as outlined in Kirkpatrick v. Preisler. Dissenting opinions were expressed by Justices Brennan, Douglas, and Marshall, highlighting differing views on the balance between population equality and practical considerations in redistricting. Overall, Mahan v. Howell is a pivotal case in the ongoing discussion about the principles and practices of electoral districting in the United States.
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.