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, residents of several counties, filed a complaint against defendants, state officers and election officials, alleging that a state statute arbitrarily and capriciously appointed representatives without reference to any logical or rational formula and that it deprived them of the equal protection of the laws in violation of U.S. Const. amend. XIV. The 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 the plaintiffs in a position of constitutionally unjustifiable inequality. The trial court granted defendants' motion to dismiss, finding that it lacked subject matter jurisdiction and that the complaint failed to state a claim upon which relief could be granted.
Whether the District Court may declare a malapportionment legislature unconstitutional without raising a political question.
The court reversed and remanded, holding 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. 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.