Baker v. Carr – Case Brief Summary

Summary of Baker v. Carr, 369 U.S. 186, 82 S. Ct. 691, 7 L. Ed. 2d 663 (1962).

Facts

Charles Baker (P) was a resident of Shelby County, Tennessee. Baker filed suit against Joe Carr, the Secretary of State of Tennessee. Baker’s complaint alleged that the Tennessee legislature had not redrawn its legislative districts since 1901, in violation of the Tennessee State Constitution which required redistricting according to the federal census every 10 years. Baker, who lived in an urban part of the state, asserted that the demographics of the state had changed shifting a greater proportion of the population to the cities, thereby diluting his vote in violation of the Equal Protection Clause of the Fourteenth Amendment.

Baker sought an injunction prohibiting further elections, and sought the remedy of reapportionment or at-large elections. The district court denied relief on the grounds that the issue of redistricting posed a political question and would therefore not be heard by the court.

Issues

  1. Do federal courts have jurisdiction to hear a constitutional challenge to a legislative apportionment?
  2. What is the test for resolving whether a case presents a political question?

Holding and Rule (Brennan)

  1. Yes. Federal courts have jurisdiction to hear a constitutional challenge to a legislative apportionment.
  2. The factors to be considered by the court in determining whether a case presents a political question are:
    1. Is there a textually demonstrable constitutional commitment of the issue to a coordinate political department (i.e. foreign affairs or executive war powers)?
    2. Is there a lack of judicially discoverable and manageable standards for resolving the issue?
    3. The impossibility of deciding the issue without an initial policy determination of a kind clearly for nonjudicial discretion.
    4. The impossibility of a court’s undertaking independent resolution without expressing lack of the respect due coordinate branches of government.
    5. Is there an unusual need for unquestioning adherence to a political decision already made?
    6. Would attempting to resolve the matter create the possibility of embarrassment from multifarious pronouncements by various departments on one question?

The political question doctrine is based in the separation of powers and whether a case is justiciable is determined on a case by cases basis. In regards to foreign relations, if there has been no conclusive governmental action regarding an issue then a court can construe a treaty and decide a case. Regarding the dates of the duration of hostilities, when there needs to be definable clarification for a decision, the court may be able to decide the case.

The court held that this case was justiciable and did not present a political question. The case did not present an issue to be decided by another branch of the government. The court noted that judicial standards under the Equal Protection Clause were well developed and familiar, and it had been open to courts since the enactment of the Fourteenth Amendment to determine if an act is arbitrary and capricious and reflects no policy. When a question is enmeshed with any of the other two branches of the government, it presents a political question and the Court will not answer it without further clarification from the other branches.

See Brown v. Board of Education for a constitutional law case brief featuring an interpretation and application of the Equal Protection Clause of the Fourteenth Amendment in an opinion involving segregation in public schools.


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