Reapportionment–Legislative Bodies–Significant Deviation from Standard of Substantial Population Equality of State Legislative Districts Is Permissible To Provide Representatives for Two Island Counties–Vigneault v. Secretary of the Commonwealth

Since Baker v. Carr, when the Supreme Court overruled a long line of earlier decisions and concluded that the relationship of the equal protection clause to a state’s power to create geographical districts for legislative representation was a justiciable issue, state apportionment plans have come under increasing judicial scrutiny. In Gray v. Sanders, the Court held invalid a Georgia primary election plan which favored voters from rural areas. Although Gray dealt with the dilution of individual voting rights rather than legislative reapportionment, it is important as the first enunciation of the now-famous “one man-one vote” test. Specifically, the Court stated that “[t]he conception of political equality from the Declaration of Independence, to Lincoln’s Gettysburg Address, to the Fifteenth, Seventeenth, and Nineteenth Amendments can mean only one thing–one person, one vote.”