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Baker v. Carr
369 U.S. 186
Author: CJ
Facts: Voters of Tennessee sought
injunction to reform the outdated legislative districting plans
and claimed the current system to be a violation of the Equal
Protection Clause of the 14th Amendment.
Previously in Colegrove v. Greene, a similar suite was brought
under Guaranty Clause (Art IV, § 4) of the Constitution and
Justice Frankfurter had ruled that this issue was nonjusticiable.
Procedure: The lower court ruled that this
issue raised a political question and therefore it was
nonjusticiable.
Issue: Did this claim raise a
political question making this lawsuit beyond the power of the
court?
Holding: No
Rationale: According to Justice
Brennan, it is a mistake to think that every issue concerned with
legislative districting raises political questions. The
case in Colegrove was brought under Guaranty Clause and this
clause is of such political nature that it is nonjusticiable.
But the current case is brought under Equal Protection Clause and
the court has to power to decide under this issue.
According to Justice Brennan, this case involves no factors that
would render it to be a political issue and beyond the power of
the court. “The question here is the consistency of
state action with Federal Constitution. We have no question
decided, or to be decided, by a political branch of government
coequal with this Court. Nor do we risk embarrassment of
our government abroad, or grave disturbance at home, if we take
issue with Tennessee as to the constitutionality of her action
here challenged. Nor need the appellants, in order to
succeed in this action, ask the court to enter upon policy
determinations for which judicially manageable standards are
lacking.”
Dissent: This case has all the elements of
the case in Colegrove and it is brought in just under a different
title. The issues that this case raises are political in
nature and require the type of training that the judges cannot be
expected to have. Therefore, this case should have been
nonjusticiable.
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