In Re Apportionment of Delta County Board of Commissioners—1982

Commencing with Mahan v Ho well 1 the United States Supreme Court distinguished dual constitutional standards in apportionment reviews. Congressional apportionment is governed by Art I, § 2 of the United States Constitution, and requires a good-faith effort to achieve absolute population equality in the drafting of congressional districts. On the other hand, legislative bodies within the states are governed by the Equal Protection Clause of the Fourteenth Amendment which permits more flexibility of the constitutional principle of equality among election districts.

The Court went on to hold:

"The…