Mahan v. Howell 410 U.S. 315 (1973)
MAHAN v. HOWELL 410 U.S. 315 (1973)
The ideal reapportionment, following reynolds v. sims (1964), would establish state legislative districts of equal populations. The question remained: How much deviation from pure mathematical equality would be tolerated? In Mahan, the Supreme Court approved, 6–3, a deviation of sixteen percent in the districting of Virginia's lower house, justified by the state's "policy of maintaining the integrity of district lines."
In congressional districting, no such deviation from equality is tolerated (White v. Weiser, 1973). However, state legislative districting may include de minimis departures from equality (up to around ten percent) without any justification (White v. Regester, 1973).
Kenneth L. Karst