Karcher v. Daggett

Karcher v. Daggett
Litigants	Karcher v. Daggett
Arguedate	February 22, 1983
Decide date	June 23, 1983
Citation	462 U.S. 725
Court	Supreme Court of the United States
Prior	District Court for the District of New Jersey
Holding	Population deviations in congressional redistricting must be closely scrutinized and justified by legitimate state objectives
Majority	Rehnquist
Joinmajority	Burger, White, Powell, O'Connor
Concurrence	Brennan
Dissent	Stevens
Lawsapplied	U.S. Constitution, Fourteenth Amendment, Article I

Karcher v. Daggett

Karcher v. Daggett was a 1983 Supreme Court decision concerning reapportionment and equal representation under the Fourteenth Amendment applied to United States House of Representatives districting in New Jersey. The case addressed permissible population deviations among congressional districts and refined standards from prior rulings such as Wesberry v. Sanders and Reynolds v. Sims. The Court evaluated whether minor numerical disparities could be justified by legitimate state objectives like preserving political subdivision lines or respecting incumbency.

Background

The controversy arose during the 1980s redistricting cycle following the 1980 United States Census, when population shifts prompted several states to redraw congressional district boundaries. The dispute invoked precedents including Wesberry v. Sanders (requiring approximate equality in House of Representatives districts), Reynolds v. Sims (one person, one vote), and Gaffney v. Cummings (use of aggregate data for partisan considerations). Petitioners and respondents referenced procedures from the New Jersey Legislature, the role of the Governor of New Jersey, and actions by the New Jersey Supreme Court before the U.S. Supreme Court's review.

Facts of the Case

Plaintiffs challenged a New Jersey congressional plan enacted by the New Jersey Legislature and signed by the Governor of New Jersey after the 1980 Census reapportionment. The plan produced maximum population deviations among congressional districts that were numerically small but measurable. Plaintiffs, including named individuals and registered voters from affected districts, alleged violations of the Equal Protection Clause of the Fourteenth Amendment and sought judicial relief in the United States District Court for the District of New Jersey. Defendants included state officials tasked with implementing the plan, seeking deference for legislative reapportionment choices and invoking interests such as maintaining county and municipal boundaries and protecting incumbent constituencies.

Legal Issues

Central legal questions included whether the population deviations exceeded constitutional tolerances established by prior decisions like Wesberry v. Sanders and whether the State bore the burden of proving that deviations were necessary and related to legitimate state objectives. Additional issues involved the standard of review applicable to redistricting under the Equal Protection Clause, the evidentiary burden in proving purposeful discrimination or arbitrary malapportionment, and the extent to which considerations such as preserving political subdivisions or protecting incumbents could justify deviation from perfect numerical equality.

Supreme Court Decision

In a plurality opinion authored by Chief Justice William Rehnquist, the Court reversed the lower court's validation of the New Jersey plan. The majority held that the State failed to justify population deviations totaling a specified small percentage, emphasizing that where deviations are challenged, the State must demonstrate that deviations are necessary to achieve legitimate state objectives. The judgment remanded for further proceedings consistent with the requirement that legislative reapportionment adhere closely to the principles established in prior cases including Wesberry v. Sanders and Reynolds v. Sims.

Reasoning and Opinions

The majority emphasized strict scrutiny of numerical deviations in congressional districting and required concrete, articulable justifications tied to legitimate objectives such as preserving county lines or maintaining communities of interest. Chief Justice Rehnquist contrasted permissible practical considerations with impermissible attempts to entrench partisan advantage, referencing standards from Gomillion v. Lightfoot and Davis v. Bandemer. Justice William Brennan filed a concurring opinion stressing alternative reasoning about intent and effects, while Justice John Paul Stevens dissented, arguing for greater deference to legislative judgments and a more forgiving approach to small deviations given practical constraints and precedents like White v. Weiser.

Impact and Legacy

The decision sharpened the burden on states defending population deviations in congressional redistricting and influenced subsequent litigation over apportionment and election law disputes. Karcher v. Daggett contributed to jurisprudence considered in later cases addressing partisan gerrymandering and redistricting, including litigation before the United States Supreme Court and the role of lower federal courts and state judiciaries. It remains a reference point in debates involving the 1980 United States Census, later censuses, and redistricting cycles involving actors such as state legislatures, governors, and litigants seeking remedies under the Fourteenth Amendment and the framework established by Wesberry v. Sanders. Baker v. Carr and subsequent reapportionment cases continued to shape the contours of one person, one vote after this ruling.

Category:United States Supreme Court cases Category:United States Supreme Court cases of the Burger Court