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Law School Case Brief

Karcher v. Daggett - 462 U.S. 725, 103 S. Ct. 2653 (1983)

Rule:

State legislative policies will be deferred to, so long as they are consistent with constitutional norms, even if they require small differences in the population of congressional districts. Any number of consistently applied legislative policies might justify some variance, including, for instance, making districts compact, respecting municipal boundaries, preserving the cores of prior districts, and avoiding contests between incumbent representatives. As long as the criteria are nondiscriminatory, these are all legitimate objectives that on a proper showing could justify minor population deviations. The state must, however, show with some specificity that a particular objective requires the specific deviations in its plan, rather than simply relying on general assertions. 

Facts:

As a result of the 1980 census, the New Jersey Legislature reapportioned the State's congressional districts. The reapportionment plan contained 14 districts, with an average population per district of 526,059, each district, on the average, differing from the "ideal" figure by 0.1384%. The largest district (Fourth District) had a population of 527,472, and the smallest (Sixth District) had a population of 523,798, the difference between them being 0.6984% of the average district. In a suit by a group of individuals challenging the plan's validity, the District Court held that the plan violated Art. I, § 2, of the Constitution because the population deviations among districts, although small, were not the result of a good-faith effort to achieve population equality.

Issue:

Did the district court err in declaring the reapportionment unconstitutional?

Answer:

No

Conclusion:

The Court held that there were no de minimus population variations that were practicably avoidable but which met the standard of art. I, § 2. Because the population deviation could have been reduced by shifting a handful of municipalities from one district to another, the citizens group met its burden of showing that the plan did not come as nearly as practicable to population equality. The district court did not err in finding that the state failed to demonstrate any causal relationship between its avowed goal of preserving minority voting strength in one district and the population variances in the other districts.

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