ABSTRACT
State legislatures had no constitutional obligation
before i960 to aim at equal populations in drawing leg-
islative and congressional districts. In a series of rulings
in the 1960s, however, the Supreme Court held that
"substantially equal legislative representation" was a
"fundamental principle" under the Constitution. The
doctrine, at first known as "one man, one vote" even
though the opinion says "one person, one vote," forced
legislatures and federal courts to be precise in adjusting
the populations of legislative and congressional dis-
tricts.