Gray v. Sanders
Encyclopedia
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 for legislative districting.
, brought a lawsuit which challenged the legality of the County Unit System
. 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 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 938 people or .05% of the state's population and .48% (1 unit vote) of the unit system. The system managed to give 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. The Supreme Court
granted certiorari in this case despite having refused to hear previous challenges to the Unit System.
wrote the majority opinion and said "The concept of political equality...can mean only one thing—one 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 investigate the constitutional requirements for legislative districts.
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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1963), was a Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case dealing with equal representation in regard to the American
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
election system and formulated the famous "one person, one vote" standard for legislative districting.
Background
James Sanders, a voter in Fulton County, GeorgiaFulton County, Georgia
Fulton County is a county located in the U.S. state of Georgia. Its county seat is Atlanta, the state capital since 1868 and the principal county of the Atlanta metropolitan area...
, brought a lawsuit which challenged the legality of the County Unit System
County Unit System
The County Unit System was used by the U.S. state of Georgia to determine a victor in its primary elections.Each county was given a certain number of votes and the candidate who received the highest number of votes in that county won all their 'unit votes', under a form of block voting...
. 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
Georgia (U.S. state)
Georgia is a state located in the southeastern United States. It was established in 1732, the last of the original Thirteen Colonies. The state is named after King George II of Great Britain. Georgia was the fourth state to ratify the United States Constitution, on January 2, 1788...
officeholders.
Sanders argued that the County Unit System gave unequal 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
Echols County, Georgia
Echols County is a county located in the U.S. state of Georgia. It is part of the Valdosta, Georgia Metropolitan Statistical Area. As of 2000, the population is 3,754. The 2007 Census Estimate shows a population of 4,093. The county seat is Statenville...
, the smallest county in Georgia at the time, had 938 people or .05% of the state's population and .48% (1 unit vote) of the unit system. The system managed to give 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. The Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
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. DouglasWilliam O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
wrote the majority opinion and said "The concept of political equality...can mean only one thing—one 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
John Marshall Harlan II
John Marshall Harlan was an American jurist who served as an Associate Justice of the Supreme Court from 1955 to 1971. His namesake was his grandfather John Marshall Harlan, another associate justice who served from 1877 to 1911.Harlan was a student at Upper Canada College and Appleby College and...
dissented, suggesting the case be sent back for retrial, which would investigate the constitutional requirements for legislative districts.
Aftermath
GeorgiaGeorgia (U.S. state)
Georgia is a state located in the southeastern United States. It was established in 1732, the last of the original Thirteen Colonies. The state is named after King George II of Great Britain. Georgia was the fourth state to ratify the United States Constitution, on January 2, 1788...
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.
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.External links
- Gray v. Sanders FindLaw page on the Supreme Court decision ending the County Unit System