The Supreme Court declines to resolve a difficult 1-person-1-vote question.

The Court denied cert. in Lepak v. City of Irving, which presented "the long-standing issue of which population basis should be used in deciding whether a redistricting plan violates the one-person, one-vote mandate."

The dispute is between using an area’s total population in equalizing districts, or using only the total of eligible voters. In a dispute over city elections in Irving, lower courts used total population, which meant that one district which had a larger number of non-citizen Hispanics would nevertheless have them included in its count.