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Published by The University of Alabama,
The University of Alabama at Birmingham,
and the Alabama Department of Archives and History

Spring 1962: Baker v. Carr

4/25/2012

 
On March 26, 1962, the Supreme Court handed down a landmark case, temporarily distracting Alabamians from the conflict brewing across the region. Years earlier, Charles Baker, a resident of Shelby County, Tennessee, brought suit against the state for its outdated voting districts, unchanged in over fifty years. As southern cities grew in size, urban counties like Shelby, home to the city of Memphis, began to eclipse rural counties in population. Yet elected officials, afraid that urban voters might include enfranchised African Americans and white liberals, refused to amend voting apportionment to reflect changing demographics. In Tennessee, Baker argued, the districts outlined in the 1901 state constitution provided for an unequal distribution of political power. The United States District Court dismissed the suit, citing lack of judicial authority—in essence, the court argued that the federal government had no responsibility for state political decisions.
The Supreme Court heard arguments by Baker, who fronted suits from the residents of several urban counties, and Joe C. Carr, the Tennessee Secretary of State. In a 6-2 decision, Justice William J. Brennan Jr. stated that the District Court had erred in dismissing the case; he argued that the federal government had jurisdiction over cases of malapportionment, since they concerned the right to vote. In his concurrent opinion, Justice William O. Douglas made the ruling’s impact clear: “If…the reapportionment statute no longer serves its original purpose of securing to the voter the full constitutional value of his franchise...the doors of the courts must be open to him.”

The decision relied on a number of precedents, including one from Alabama, Gomillion v. Lightfoot. In 1960 the Court ruled in favor of Charles Gomillion, a black civil rights leader from Tuskegee who challenged a municipal redistricting that reduced the strength of the black voting community. In the decision, mirrored in Baker, the Court found that the state had a responsibility to preserve constitutional rights in municipal decisions. The rulings in Gomillion and Baker stated that the federal government had the authority to intervene in state government to preserve political equality. African Americans now had a powerful weapon to fight for the franchise.

Within a month, a federal court in Georgia drew on Baker to strike down the most notorious voting system in the South, Georgia’s infamous county unit system. In an attempt to preserve the political power of conservative, majority-white electorates, state leaders gave each county a “unit” vote, awarded to the political candidate who won a plurality of the votes in any given election. The system gave small rural counties the same political power as growing urban population centers. The federal decision, handed down in June 1962, failed to overturn the county-based voting system as a whole, but the court warned that the state’s voting provisions had “led to rural political control and had virtually nullified the power of Negroes, liberals and middle-of-the-road voters.” Atty. Gen. Robert F. Kennedy praised the fairness of the ruling and warned that “the same unfair situation exists in many other states.”

Despite Gomillion and Baker, Alabama failed to address its own malapportionment. Like Tennessee, Georgia, and other southern states, Alabama’s rural counties had decreased in population as urban centers like Huntsville, Birmingham, and Mobile boomed. By the mid-1960s, voting districts outlined by the state’s 1901 constitution were woefully outdated. In 1964 the Supreme Court handed down Reynolds v. Sims, a sweeping denunciation of the state’s voting system in a broad case that also involved plaintiffs from New York, Colorado, Maryland, Virginia, and Delaware. Chief Justice Earl Warren argued that “[once] the geographical unit for which a representative is to be chosen is designated, all who participate in the election are to have an equal vote—whatever their race, whatever their sex, whatever their occupation, whatever their income, and whatever their home may be in that geographical unit.” Alabama’s failure to update its congressional apportionment had “resulted in a minority strangle hold [sic] on the state Legislature.”

The ruling challenged policies of gerrymandering and creative construction that attempted to create political minorities among certain segments of the population. In trying to weaken urban areas with majority black and liberal voters, conservative state officials denied the right to a free and fair election to a substantial group. Chief Justice Warren enunciated a core tenet of the struggle for African American enfranchisement: “The conception of political equality from the Declaration of Independence to Lincoln’s Gettysburg Address, to the 15th, 17th and 19th Amendments can mean only one thing—one person, one vote.” As civil rights activists turned to the federal government for legislation that would protect basic human rights, the vote became an essential weapon in the fight for equality. The Supreme Court’s decision in Baker v. Carr, along with subsequent rulings, empowered the federal government to provide much needed assistance in the struggle for voting rights.

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    Becoming Alabama:
    Civil Rights Movement

    Author

    Matthew L. Downs (PhD, Alabama) is an adjunct professor of history at Birmingham-Southern College. His dissertation focused on the federal government's role in the economic development of the Tennessee Valley.


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