high share of the Senate having been appointed to fill vacancies. During one session, fourteen out of fifteen senators had been selected to fill vacancies. In 1836, tensions rose over the State Senate's composition. That year, the Democratic Party won 53% of the statewide vote for the electoral college, but ended up with only nineteen of forty electors. When the Whig electors planned to elect an all-Whig State Senate, the Democratic electors absconded, denying the electoral college a quorum. The refusal to elect a State Senate also prevented the election of a Governor, as Maryland's governors were elected by the legislature. Ultimately, however, the Democrats' position weakened following the State House elections the following month, when the Whigs won an overwhelming majority. The electors returned, providing a quorum, and an all-Whig Senate was elected. The controversy ultimately resulted in long-term changes to the body in 1838. The electoral college was abolished, terms were lengthened to six years with rotating elections such that a third of the senate would be elected every two years, a single Senator was chosen by direct election from each county and the City of Baltimore, and vacancies were filled by special elections. The Senate no longer acted as the Governor's Council, although they would continue to confirm the Governor's appointments. Constitutional changes altered this new system slightly in 1851, when terms were shortened to four years, and 1864, when Baltimore City was given three Senate districts rather than one, but substantial change to the structure of the Senate did not come again until 1964. In 1964, the Supreme Court ruled in Reynolds v. Sims that state legislative seats must be apportioned on the principle of one man, one vote. A number of state legislatures, including Maryland, had systems based on geography rather than population, and the court rules that this violated the 14th Amendment. Disproportionate population growth across Maryland since 1838 meant that the principle of one seat per county gave the voters of some counties, such as those on the eastern shore, disproportionate representation. Other counties, especially those in suburban areas, were underrepresented. A special session of the legislature in 1965 changed the Senate to represent 16 districts and reapportioned the seats, again by county, but did so in such a way as to make the representation more proportional to population than it had been. Thus, the eastern shore, which had previously elected nine senators,