TENNANT v. JEFFERSON COUNTY COMMISSION

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Case Basics
Docket No. 
11-1184
Petitioner 
Natalie E. Tennant, Earl Ray Tomblin, Jeffrey Kessler, and Richard Thompson, in their official capacities.
Respondent 
Jefferson County Commission, Patricia Noland (as an individual and on behalf of all others similarly situated), and Dale Manuel (as an individual and on behalf of all others similarly situated)
Decided By 
Term:
Facts of the Case 

In January 2012, the Jefferson County Commission brought suit against West Virginia Secretary of State Natalie E. Tennant, Governor Earl Ray Tomblin, State Senate President Jeffrey Kessler, and Speaker Richard Thompson of the West Virginia House of Delegates, each in his or her official capacity. The county commission and two of its commissioners claimed that the State’s congressional apportionment statute enacted after the 2010 census violates Article I Section 2 of the US Constitution. The new statute created voting districts with significant disparities in population, violating the constitutional principle of “one person, one vote.”

Since the plaintiffs showed that the population disparities could have been reduced, the United States District Court for the Southern District of West Virginia held that the apportionment is not constitutional and declared it null and void. The state officials appealed directly to the United States Supreme Court.

Question 

Does the population disparity in West Virginia’s apportionment of voting districts violate Article I Section 2 of the U.S. Constitution?

Conclusion 
Decision: 0 votes for , 0 vote(s) against
Legal provision: Article I Section 2 U.S. Constitution

No. The Court, in a per curiam opinion, reversed the district court’s decision. The Court held that the lower court failed to defer to West Virginia’s reasonable exercise of political judgment. Even though the state could have chosen a re-districting plan with less of a population disparity, none of the other plans satisfied the state’s legitimate objectives. Therefore, the minor disparity in population was justified to achieve those objectives.

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TENNANT v. JEFFERSON COUNTY COMMISSION. The Oyez Project at IIT Chicago-Kent College of Law. 10 September 2014. <http://www.oyez.org/cases/2010-2019/2011/2011_11_1184>.
TENNANT v. JEFFERSON COUNTY COMMISSION, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2011/2011_11_1184 (last visited September 10, 2014).
"TENNANT v. JEFFERSON COUNTY COMMISSION," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 10, 2014, http://www.oyez.org/cases/2010-2019/2011/2011_11_1184.