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Gray v. Sanders

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Significance: The Supreme Court invalidated a Georgia election system as not representative of its voters and introduced the one person, one vote concept.


By an 8-1 vote, the Court invalidated Georgia's county unit primary election system, which severely impacted urban areas, finding it to be unconstitutional under the equal protection clause of the Fourteenth Amendment. Justice William O. Douglas wrote the majority opinion with separate concurrences by Justices Potter Stewart and Tom C. Clark. Douglas viewed Gray as a voting rights case without legislative reapportionment implications, a view that Stewart and Clark underscored. Douglas also introduced the one person, one vote concept, declaring that equality of representation was necessary for political equality. Gray proved to be a critical link between Baker v. Carr (1962) and Reynolds v. Sims (1964), one of a group of reapportionment cases. In Gray, Justice John M. Harlan II dissented as he would in the reapportionment cases, arguing that this issue plunged justices further into the political thicket and that the superiority of the federal to state courts had not been proven.