every criminal suspect and required police to give criminal suspects what became known as a "Miranda warning" in which suspects are notified of their right to an attorney and their right to silence. Warren incorporated some suggestions from Brennan, but his holding in Miranda was most influenced by his past experiences as a district attorney. Unlike many of the other Warren Court decisions, including Mapp and Gideon, Miranda created standards that went far beyond anything that had been established by any of the states. Miranda received a strong backlash from law enforcement and political leaders. Conservatives angrily denounced what they called the "handcuffing of the police." Reapportionment (one man, one vote) In 1959, several residents dissatisfied with Tennessee's legislative districts brought suit against the state in Baker v. Carr. Like many other states, Tennessee had state legislative districts of unequal populations, and the plaintiffs sought more equitable legislative districts. In Colegrove v. Green (1946), the Supreme Court had declined to become involved in legislative apportionment and instead left the issue as a matter for Congress and the states. In Gomillion v. Lightfoot (1960), the Court struck down a redistricting plan designed to disenfranchise African-American voters, but many of the justices were reluctant to involve themselves further in redistricting. Frankfurter insisted that the Court should avoid the "political thicket" of apportionment and warned that the Court would never be able to find a clear formula to guide lower courts. Warren helped convince Associate Justice Potter Stewart to join Brennan's majority decision in Baker v. Carr, which held that redistricting was not a political question and so federal courts had jurisdiction over the issue. The opinion did not directly require Tennessee to implement redistricting but instead left it to a federal district court to determine whether Tennessee's districts violated the Constitution. In another case, Gray v. Sanders, the Court struck down Georgia's County Unit System, which granted disproportional power to rural counties in party primaries. In a third case, Wesberry v. Sanders, the Court required states to draw congressional districts of equal population. In Reynolds v. Sims (1963), the chief justice wrote what biographer Ed Cray terms "the most influential of the 170 majority opinions [Warren] would write." While eight of the nine justices had voted to require congressional districts of equal population in Wesberry, some of the justices were reluctant to require state legislative districts to be of equal population. Warren