Landmark Supreme Court Case: Baker v. Carr (1962)

by Kwaisi France · July 7, 2020

Baker v. Carr (1962) is the 110th landmark Supreme Court case, fourth in the Elections module, featured in the KTB Prep American Government and Civics series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:

The Supreme Court

The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.

The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.

The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.

Court of Appeals

In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.

The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.

A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.

District Courts

The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.

Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.

There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.

Bankruptcy Courts

Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.

Baker v. Carr (1962)

Baker Facts:

Plaintiff Charles Baker was a Republican who lived in Shelby County, Tennessee, and had served as the mayor of Millington, Tennessee, near Memphis. The Tennessee State Constitution required that legislative districts for the Tennessee General Assembly be redrawn every ten years according to the federal census to provide for districts of substantially equal population (as was to be done for congressional districts). Baker’s complaint was that Tennessee had not redistricted since 1901, in response to the 1900 census.

By the time of Baker’s lawsuit, the population had shifted such that his district in Shelby County had about ten times as many residents as some of the rural districts. The votes of rural citizens were overrepresented compared to those of urban citizens. Baker’s argument was that this discrepancy was causing him to fail to receive the “equal protection of the laws” required by the Fourteenth Amendment.

Defendant Joe Carr was sued in his position as Secretary of State for Tennessee. Carr was not the person who set the district lines – the state legislature had done that – but was sued ex officio as the person who was ultimately responsible for the conduct of elections in the state and for the publication of district maps.

The state of Tennessee argued that the composition of legislative districts was essentially a political question, not a judicial one, as had been held by Colegrove v. Green’, a plurality opinion of the Court in which Justice Felix Frankfurter declared that “Courts ought not to enter this political thicket.” Frankfurter believed that relief for legislative malapportionment had to be won through the political process.

Baker Legal Questions and Answers

Q: Did the Supreme Court have jurisdiction over questions of legislative apportionment?

A: Yes. State reapportionment claims are justiciable in federal court.

Baker Conclusion

6-2 holding the redistricting of state legislative districts is not a political question, and thus is justiciable by the federal courts. The Court can intervene to correct constitutional violations in state administration and the officers through whom state affairs are conducted; thus, federal courts are enabled to hear redistricting cases.

In an opinion which explored the nature of “political questions” and the appropriateness of Court action in them, the Court held that there were no such questions to be answered in this case and that legislative apportionment was a justiciable issue. In his majority opinion, Justice Brennan provided past examples in which the Court had intervened to correct constitutional violations in matters pertaining to state administration and the officers through whom state affairs are conducted. Brennan concluded that the Fourteenth Amendment equal protection issues which Baker and others raised in this case merited judicial evaluation.

State Bar of Georgia on Baker v. Carr (1962)

Next Elections Case: Reynolds v. Sims (1964)

Previous Elections Case: Luther v. Borden (1849)

Next Case: Engel v. Vitale (1962)

Previous Case: Mapp v. Ohio (1961)

Comments

comments