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The BAKER et al. v. CARR et al. case involves a civil action brought under 42 U.S.C. §§ 1983 and 1988 to address the alleged deprivation of federal constitutional rights. The case concerns the apportionment of members of the General Assembly among Tennessee's counties and the alleged denial of equal protection of the laws under the Fourteenth Amendment. The Supreme Court found that the dismissal of the case by a three-judge court was in error and remanded the case to the District Court for trial and further proceedings. The plaintiffs allege that the 1901 Apportionment Act, which allocated legislative representation in Tennessee, was unconstitutional and obsolete due to population changes since 1900 and the failure of the legislature to reapportion itself. The District Court dismissed the case due to lack of jurisdiction and failure to state a claim, but the court of appeals found that the District Court had jurisdiction over the case. The present case alleges a violation of the Fourteenth Amendment, which falls under the federal judicial power defined in Article III, Section 2 of the Constitution. The District Court has jurisdiction over the federal constitutional claim asserted in this case.
In summary, the case challenges Tennessee's state representative and senatorial seat apportionment system under the Fourteenth Amendment's Equal Protection and Due Process Clauses. The Tennessee apportionment system violates the Equal Protection Clause, and judicial intervention is necessary to prevent continued discrimination. The Court's ruling emphasizes the importance of representative government and upholding national rights. The case has been remanded to the three-judge court for a formal determination.
The Court is generally hesitant to intervene in state political institutions, but discrimination against the right to vote is an exception. Claims challenging state distribution of powers, delegation of power to municipalities, adoption of the referendum as a legislative institution, and restriction upon the power of state constitutional amendment have been held non-justiciable. The present case is non-justiciable as it is essentially a Guarantee Clause claim disguised under a different label. The appellants' claim of discrimination based on legislative underrepresentation is justiciable, but the guarantee of equal protection cannot be used to enforce a political conception of representative government. Judges should not use their personal views of political wisdom to interpret the Constitution. The article discusses historical attempts to address electoral inequality in England and the US, with rural areas having greater per capita representation compared to urban areas. The Equal Protection Clause provides little guidance on the issue, and federal courts should not intervene in apportionment cases. The McCanless case in Tennessee allowed a suit for a declaratory judgment but denied coercive relief. Justices Harlan and Frankfurter dissent from the majority's decision, arguing that it goes against judicial history by involving federal courts in an area of state concerns. The Supreme Court should exercise self-restraint when it comes to state tax statutes and regulatory measures, and even more so when it involves a state's freedom to structure its own legislative branch.
The state legislature has the authority to apportion political representatives, and as long as there is a rational policy for retaining an existing apportionment, it does not violate the Fourteenth Amendment. The case cannot proceed to trial as there is no recognizable constitutional claim. Justice Harlan's dissenting opinion argues that the formula used to allocate seats in an election district is flawed, and the lower court may have erred in using it. Electoral disparities in Tennessee cannot be judged solely on statistics, and other factors must be considered. The existing apportionment pattern may be a deliberate policy decision to promote stability, and the Legislature's decision to preserve the electoral strength of rural interests over urban population growth is a valid legislative choice and not unconstitutional. The appellants' claims are not supported by constitutional principles.
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