Brown v. Thomson (1982)

Docket
82-65
Decided
1982-01-01

Summary

Question: Did the State of Wyoming violate the equal protection clause of the Fourteenth Amendment by allocating one of its state House seats to a county with a population considerably lower than the average population per state representative? Conclusion: The Court upheld the Wyoming apportionment scheme and found no Fourteenth Amendment violations. Justice Powell argued that using counties as legislative districts and assuring at least one representative per county supported "substantial and legitimate state concerns." Since the population variations in the Wyoming plan were the result of the consistent application of a nondiscriminatory and legitimate state policy, the plan was consistent with the Constitution. Any dilution of voting strength which the constituents of the other sixty-three representatives may have experienced as a result of Niobrara's relatively small population was minimal and irrelevant given the advantages of the Wyoming scheme.

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