Facts of the Case

The WMCA, acting on behalf of several New York City registered voters, challenged the constitutionality of Article III, Sections 2-5 of the New York State constitution alleging that its apportionment formula resulted in unfair weighting of both state legislature houses by favoring lesser populated rural areas over densely populated urban centers. On appeal from a dismissal of their complaint by a three-judge district court, the Supreme Court granted the WMCA certiorari.

Question

Did the apportionment formula contained in Article III, Sections 2-5, of the New York State constitution violate the Fourteenth Amendment's Equal Protection Clause?

Conclusion

Yes. In a 7-to-3 decision, the Court began by noting that this case was property before it since no other political relief was available to the WMCA. The Court then held that New York's apportionment formula violated the Equal Protection Clause since it did not apportion the state's senate and assembly substantially on a population basis. Consequently, New York's legislative apportionment scheme significantly undervalued the weight of urban area voters as compared with their rural and less densely populated counterparts. This practice constituted a form of geographical discrimination that violated notions of equal protection.