A federal court cannot pronounce any statute, either of a state or of the United States, void, because it is irreconcilable with the United States Constitution, except as it is called upon to adjudge the legal rights of litigants in actual controversies. Have the plaintiffs alleged such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions? This is the gist of the question of standing.
Plaintiffs Baker and several residents of various Tennessee counties, each qualified to vote for members of the Tennessee legislature representing his county, instituted a class action in the United States District Court for the Middle District of Tennessee for a declaration that the Tennessee Apportionment Act of 1901 was unconstitutional and for an injunction restraining defendants, state officers and election officials, from conducting any further elections under the act. Plaintiffs alleged that the Act violated the Fourteenth Amendment in its disregard of the standard of apportionment prescribed by the state's constitution or of any standard, thereby effecting a gross disproportion of representation to voting population, and placed plaintiffs in a position of constitutionally unjustifiable inequality. The district court, sitting as a three-judge court, dismissed the action on the ground that it lacked jurisdiction of the subject matter and that the complaint failed to state a claim upon which relief could be granted.
Did the complaint fail to state a cause of action upon which relief could be granted?
The Court held that the complaint's allegations of a denial of equal protection presented a justiciable constitutional cause of action upon which plaintiffs were entitled to a trial and a decision. According to the Court, the right that plaintiffs asserted was within the reach of judicial protection under U.S. Const. amend. XIV. The Court further found that if discrimination were sufficiently shown, the right to relief under the Equal Protection Clause would not be diminished by the fact that the discrimination related to political rights. Thus, the decision dismissing plaintiffs' complaint for lack of subject matter jurisdiction and failure to state a claim upon which relief could be granted was reversed and remanded.