Gray v. Sanders

Last updated

Gray v. Sanders
Seal of the United States Supreme Court.svg
Argued January 17, 1963
Decided March 18, 1963
Full case nameGray, Chairman of the Georgia State Democratic Executive Committee, et al. v. Sanders
Citations372 U.S. 368 ( more )
83 S. Ct. 801; 9 L. Ed. 2d 821; 1963 U.S. LEXIS 1944
Case history
PriorAppeal from the United States District Court for the Northern District of Georgia.
Subsequent203 F. Supp. 158 (N.D. Ga. 1962), judgment vacated and case remanded.
Holding
State elections must adhere to the "one person, one vote" principle.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black  · William O. Douglas
Tom C. Clark  · John M. Harlan II
William J. Brennan Jr.  · Potter Stewart
Byron White  · Arthur Goldberg
Case opinions
MajorityDouglas, joined by Warren, Black, Clark, Brennan, Stewart, White, Goldberg
ConcurrenceStewart, joined by Clark
DissentHarlan
Laws applied
U.S. Const. amend. XIV
This case overturned a previous ruling or rulings
Colegrove v. Green , 328 U.S. 549(1946)

Gray v. Sanders, 372 U.S. 368 (1963), was a Supreme Court of the United States case dealing with equal representation in regard to the American election system and formulated the famous "one person, one vote" standard applied in this case for "counting votes in a Democratic primary election for the nomination of a United States Senator and statewide officers — which was practically equivalent to election."

Contents

Background

James O'Hear Sanders, a businessman and voter in Fulton County, Georgia, brought a lawsuit which challenged the legality of the County Unit System. The suit, Sanders v. Gray, was filed in the U.S. District Court for the Northern District of Georgia. [1] James H. Gray, the chairman of the State Executive Committee of the Democratic Party, was one of the named defendants as the suit focused on the Democratic party primary elections which usually determined the selection of Georgia officeholders.

Sanders argued that the County Unit System gave unequal and preferential voting power to smaller counties. Rural counties, which accounted for one-third of Georgia's population, accounted for a majority of County Unit votes. Fulton County had 14.11% of Georgia's population at that time, but only 1.46% (6 unit votes) of the 410 Unit Votes. Echols County, Georgia, the smallest county in Georgia at the time, had 1,876 [2] people or .05% of the state's population and .48% (1 unit vote) of the unit system. The system gave votes to Fulton County at a proportion of one-tenth the county population while giving Echols County a vote which was 10 times the population of the county.

In the Northern District of Georgia, Sanders v. Gray was heard by judges Elbert Tuttle, Griffin Bell, and Frank Arthur Hooper. [1]

The Supreme Court granted certiorari in this case despite having refused to hear previous challenges to the Unit System.

The court's decision

By a vote of 8 to 1, the court struck down the County Unit System. Justice William O. Douglas wrote the majority opinion and said "The concept of political equality...can mean only one thingone person, one vote". The court found that the separation of voters in the same election into different classes was a violation of the 14th Amendment's guarantee of equal protection. Justice John Marshall Harlan II dissented, suggesting the case be sent back for retrial, which would have investigated the constitutional requirements for legislative districts.

Aftermath

Georgia had the option of modifying the County Unit System to make it more equal, but instead the state decided to move to using the popular vote in primary elections.[ citation needed ]

See also

Further reading

Toplak, Jurij. Gray v. Sanders : 372 U.S. 368 (1963). In: Schultz, David W (Ed.). Encyclopedia of the Supreme Court. New York: Facts on file, 2005, pp. 188–189.

Related Research Articles

<span class="mw-page-title-main">Earl Warren</span> Chief Justice of the United States from 1953 to 1969

Earl Warren was an American lawyer, politician, and jurist who served as the 30th governor of California from 1943 to 1953 and as the 14th Chief Justice of the United States from 1953 to 1969. The Warren Court presided over a major shift in American constitutional jurisprudence, which has been recognized by many as a "Constitutional Revolution" in the liberal direction, with Warren writing the majority opinions in landmark cases such as Brown v. Board of Education (1954), Reynolds v. Sims (1964), Miranda v. Arizona (1966), and Loving v. Virginia (1967). Warren also led the Warren Commission, a presidential commission that investigated the 1963 assassination of President John F. Kennedy. He served as Governor of California from 1943 to 1953, and is the last chief justice to have served in an elected office before nomination to the Supreme Court. Warren is generally considered to be one of the most influential Supreme Court justices and political leaders in the history of the United States.

<span class="mw-page-title-main">Echols County, Georgia</span> County in Georgia, United States

Echols County is a county located in the southeastern part of the U.S. state of Georgia. As of the 2020 census, the population was 3,697. The county seat is Statenville. Since 2008, Statenville is a disincorporated municipality. Echols and Webster counties are the only two counties in Georgia to currently have no incorporated municipalities. The county was established in 1858 and named in honor of Robert Milner Echols (1798–1847).

Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. Along with Baker v. Carr (1962) and Reynolds v. Sims (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies.

Baker v. Carr, 369 U.S. 186 (1962), was a landmark United States Supreme Court case in which the Court held that redistricting qualifies as a justiciable question under the Fourteenth Amendment's equal protection clause, thus enabling federal courts to hear Fourteenth Amendment-based redistricting cases. The court summarized its Baker holding in a later decision as follows: "the Equal Protection Clause of the Fourteenth Amendment limits the authority of a State Legislature in designing the geographical districts from which representatives are chosen either for the State Legislature or for the Federal House of Representatives.". The court had previously held in Gomillion v. Lightfoot that districting claims over racial discrimination could be brought under the Fifteenth Amendment.

A state senator is a member of a state's senate in the bicameral legislature of 50 U.S. states, or a member of the unicameral Nebraska Legislature.

<span class="mw-page-title-main">Carl Sanders</span> American attorney and politician (1925–2014)

Carl Edward Sanders Sr. was an American attorney and politician who served as the 74th governor of Georgia from 1963 to 1967.

<span class="mw-page-title-main">Elections in Georgia (U.S. state)</span> Overview of the procedure of elections in the U.S. state of Georgia

Elections in Georgia are held to fill various state and federal seats. Regular elections are held every even year. The positions being decided each year varies, as the terms of office varies. The State Senate, State House and U.S. House will typically be up for election, as all of those positions have two-year terms. Special elections are held to fill vacated offices. Georgia is one of seven states that require a run-off election if no candidate receives a majority of the vote in a primary election. Uniquely, Georgia requires a run-off election for state and congressional offices if no candidate wins a majority of the vote in a general election; only Louisiana has a similar requirement, but it operates under a different election system.

<span class="mw-page-title-main">One man, one vote</span> Political slogan

"One man, one vote", "one person, one vote", or "one vote, one value" is a slogan the principle of equal representation in voting. This slogan is used by advocates of democracy and political equality, especially with regard to electoral reforms like universal suffrage and proportional representation.

<span class="mw-page-title-main">Government of Georgia (U.S. state)</span> Overview of the government of the U.S. state of Georgia

The state government of Georgia is the U.S. state governmental body established by the Georgia State Constitution. It is a republican form of government with three branches: the legislature, executive, and judiciary. Through a system of separation of powers or "checks and balances", each of these branches has some authority to act on its own, some authority to regulate the other two branches, and has some of its own authority, in turn, regulated by the other branches. The seat of government for Georgia is located in Atlanta.

<span class="mw-page-title-main">1966 Georgia gubernatorial election</span>

The 1966 Georgia gubernatorial election was held on November 8, 1966. After an election that exposed divisions within the Georgia Democratic Party, segregationist Democrat Lester Maddox was elected Governor of Georgia. The voting also brought future President Jimmy Carter to statewide prominence for the first time. The election was the closest in Georgia gubernatorial history; Republican candidate Bo Callaway won a plurality of the popular vote, but lost the contingent election in the Georgia General Assembly to Maddox. It was also the first time since 1916 that the Republican Party contested a gubernatorial election.

Colegrove v. Green, 328 U.S. 549 (1946), was a United States Supreme Court case. Writing for a 4–3 plurality, Justice Felix Frankfurter held that the federal judiciary had no power to interfere with malapportioned Congressional districts. The Court held that the Elections Clause in Article I, section IV of the U.S. Constitution left to the legislature of each state the authority to establish the time, place, and manner of holding elections for Congressional Representatives, and that only Congress could determine whether individual state legislatures had fulfilled their responsibility to secure fair representation for citizens.

<span class="mw-page-title-main">Elections in Alabama</span> Political elections for public offices in Alabama, USA

Elections in Alabama are authorized under the Alabama State Constitution, which establishes elections for the state level officers, cabinet, and legislature, and the election of county-level officers, including members of school boards.

<span class="mw-page-title-main">1962 Georgia gubernatorial election</span>

The 1962 Georgia gubernatorial election was held on November 6, 1962.

<span class="mw-page-title-main">1958 Georgia gubernatorial election</span>

The 1958 Georgia gubernatorial election was held on November 4, 1958.

The county unit system was a voting system used by the U.S. state of Georgia to determine a victor in statewide primary elections, as well as some Congressional elections, from 1917 until 1962.

<span class="mw-page-title-main">2016 Georgia Democratic presidential primary</span>

The 2016 Georgia Democratic presidential primary took place on March 1 in the U.S. state of Georgia as one of the Democratic Party's primaries ahead of the 2016 presidential election. The primary was an open one.

<span class="mw-page-title-main">1938 United States Senate election in Georgia</span>

The 1938 United States Senate election in Georgia took place on November 8, 1938. Incumbent Democratic U.S. Senator Walter F. George was re-elected to a third term in office, holding off a primary challenge from Eugene Talmadge and Lawrence Camp. At this time, Georgia was a one-party state. George's victory in the September 14 primary was tantamount to election, and he had only nominal opposition in the general election.

<span class="mw-page-title-main">1960 United States presidential election in Georgia</span> Election in Georgia

The 1960 United States presidential election in Georgia took place on November 8, 1960, as part of the 1960 United States presidential election. Georgia voters chose 12 representatives, or electors, to the Electoral College, who voted for president and vice president.

<span class="mw-page-title-main">2022 Georgia state elections</span>

Several elections took place in the U.S. state of Georgia in 2022. The general election was held on November 8, 2022. A runoff election for one of Georgia's seats in the United States Senate was held on December 6, 2022. The runoff was scheduled because none of the candidates for Senate received 50% of the statewide vote in the general election. In addition to the Senate seat, all of Georgia's seats in the United States House of Representatives were up for election. Also up for election were all of Georgia's executive officers and legislative seats, as well as one seat on the Georgia Public Service Commission. The Republican Party decisively won every single statewide office in Georgia except for the Federal Senate race which narrowly went Democratic in 2022.

Redistricting in Georgia is the process by which boundaries are redrawn for federal congressional and state legislative districts. Since statehood, redistricting in Georgia has been carried out by the Georgia General Assembly. It has historically been highly controversial. Critics have accused legislators of attempting to protect themselves from competition by gerrymandering districts.

References

  1. 1 2 Sanders v. Gray, 203F. Supp.158 (N.D. Ga.April 28, 1962).
  2. United States Census, 1960