Baker v. Carr

In Baker v. Carr, 369 U.S. 186 (1962), an action filed under the federal civil rights act, the plaintiffs claimed that a Tennessee apportionment statute debased their votes and denied them the equal protection of the laws guaranteed them under the federal constitution. The federal district court dismissed the action, holding that the subject matter of the action was not justiciable and the claim not legally cognizable. On certiorari to the United States Supreme Court, Justice William J. Brennan, Jr., on behalf of the Court, focused on the lower court's misunderstanding that because the plaintiffs sought to have a legislative apportionment declared unconstitutional, their action presented a nonjusticiable political question. The Court reversed the lower court's decision, holding that the apportionment challenge presented no nonjusticiable political question. In the course of Justice Brennan's discussion, he reviewed a number of federal political question cases "to expose the attributes of the doctrine--attributes which, in various settings, diverge, combine, appear, and disappear in seeming disorderliness." 369 U.S. at 210, 82 S.Ct. at 706. He emphasized that his review was "undertaken solely to demonstrate that neither singly nor collectively do these cases support a conclusion that this apportionment case is nonjusticiable, [and] we of course do not explore their implications in other contexts." Id. His review revealed that the relationship giving rise to the political question "is the relationship between the judiciary and the coordinate branches of the Federal Government, and not the federal judiciary's relationship to the States . . . ." Id. He also stressed that "deciding whether a matter has in any measure been committed by the [Federal] Constitution to another branch of government, or whether the action of that branch exceeds whatever authority has been committed, is itself a delicate exercise in constitutional interpretation, and is a responsibility of this Court as ultimate interpreter of the Constitution." Id. at 211, 82 S.Ct. at 706. With respect to the attribute of "lack of judicially discoverable and manageable standards," which his review had identified, id. at 217, 82 S.Ct. at 710, he observed that "judicial standards under the Equal Protection Clause are well-developed and familiar . . . ." Id. at 226, 82 S.Ct. at 715.