Facts of the Case

In 1961, M.O. Sims, David J. Vann (Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. The Alabama Constitution prescribed that each county was entitled to at least one representative and that there were to be as many senatorial districts as there were senators. Population variance ratios of as great as 41-to-1 existed in the Senate.

Question

Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances?

Conclusion

In an 8-to-1 decision, the Court upheld the challenge to the Alabama system, holding that Equal Protection Clause demanded "no less than substantially equal state legislative representation for all citizens...." Noting that the right to direct representation was "a bedrock of our political system," the Court held that both houses of bicameral state legislatures had to be apportioned on a population basis. States were required to "honest and good faith" efforts to construct districts as nearly of equal population as practicable.