Since 1929 The
Supreme Court of the United States ruled in that previous requirements contained within the
Apportionment Act of 1911 in relation to congressional districting and the manner of how representatives were to be elected were no longer in force, due to the enactment of the
Reapportionment Act of 1929. The result of this is that there were no requirements imposed upon the states by Congress as to how representatives were to be elected to the
House of Representatives. The Reapportionment Act of 1929 did not contain any requirements on how representatives were to be elected, including any requirements on how districts were to be drawn (if the
state legislature chose to use districts), due to the presumption by Congress that the requirements enacted by the Apportionment Act of 1911 were still in force since Congress never repealed those requirements. Due to
Wood,
Missouri (13 seats),
Kentucky (9),
Virginia (9),
Minnesota (9), and
North Dakota (2), all elected their representatives at large while
Texas elected 3 of their 21 seats at large;
New York,
Illinois, and
Ohio each elected 2 of their seats at large; and
Oklahoma,
Connecticut, and
Florida each elected 1 of their seats at large in the
1932 United States House of Representatives elections. All the states that elected some of their representatives at large (except Illinois) had gained seats from
reapportionment but continued to use their previous congressional district boundaries while electing their new representatives at large.
Arizona would continue to elect their representatives at large until
1946, even after gaining a second seat in 1943, and
New Mexico and
Hawaii would continue to elect all their representatives at large from their admission into the union until
1968 and
1970 respectively.
Alabama also elected all eight of its representatives at large in
1962. Meanwhile, those states that elected representatives from single-member districts often elected representatives from districts that were not compact, contiguous, or roughly equal in population.
Colegrove era In 1946, the Supreme Court of the United States ruled in a 4-3 decision
Colegrove v. Green that the federal courts do not have jurisdiction to interfere with malapportioned congressional districts, with Congress having the sole authority to interfere with the same. For the following fifteen years, both congressional districts and state legislative districts often had large population imbalances. The imbalance in the population of different congressional districts could have been fixed by an act of Congress but Congress failed to enact any standards and requirements concerning congressional districts and elections. Due to congressional inaction and new justices on the Supreme Court, the courts intervened in 1962 in the case
Baker v. Carr which required that all state legislative districts be of roughly equal population. The court used the
Fourteenth Amendment to the United States Constitution to justify its ruling (specifically the
Equal Protection Clause).
Wesberry v. Sanders extended
Baker to the districts of the United States House of Representatives. ==Legislative history==