Whitcomb v. Chavis

Summary

The Supreme Court considered whether Indiana's use of a multimember legislative district for Marion County violated the Equal Protection Clause by diluting the voting strength of Black and economically disadvantaged voters. The Court held that multimember districts are not per se unconstitutional and that the plaintiffs had not shown that the district operated to minimize or cancel out the voting strength of a racial or political group. The Court also rejected the theory that multimember districts inherently overrepresent their voters compared with voters in single-member districts.

Holdings

1. The controversy was not moot because the validity of the prior apportionment scheme and the District Court's retained jurisdiction presented continuing issues capable of affecting the parties and the validity of future apportionment arrangements.
2. Multi-member districts are not per se unconstitutional merely because they elect several legislators at large or because voters supporting losing candidates do not obtain legislative seats of their own.
3. The plaintiffs did not prove that Marion County's multi-member district invidiously diluted or canceled out the voting strength of Black residents of the Center Township ghetto in violation of the Fourteenth Amendment.
4. The District Court properly ordered statewide redistricting because the evidence established population disparities among Indiana's legislative districts that exceeded constitutionally permissible limits.
5. The District Court exceeded its remedial authority by invalidating all Indiana multi-member districts and broadly displacing state apportionment policy without sufficient constitutional or equitable grounds.

Questions Presented

1. Whether the appeal remained justiciable after Indiana enacted new apportionment legislation abolishing multi-member districts.
2. Whether Marion County's large, at-large multi-member legislative district violated the Equal Protection Clause by minimizing or canceling out the voting strength of Black and poor residents of the Center Township ghetto.
3. Whether multi-member districts are constitutionally invalid because they allegedly give their voters greater voting power or more effective legislative representation than voters in single-member districts.
4. Whether the District Court properly ordered statewide redistricting in light of population disparities among Indiana legislative districts.
5. Whether the District Court's remedy improperly invalidated all Indiana multi-member districts and intruded too broadly into state apportionment policy.

Disposition

reversed_and_remanded