sense, decency, and elemental justice were decisive, not stare decisis (that is, reliance on previous Court decisions), tradition, or the text of the Constitution. He wanted results that in his opinion reflected the best American sentiments. He felt racial segregation was simply wrong, and Brown, whatever its doctrinal defects, remains a landmark decision primarily because of Warren's interpretation of the equal protection clause. Reapportionment The one man, one vote cases (Baker v. Carr and Reynolds v. Sims) of 1962–1964, had the effect of ending the over-representation of rural areas in state legislatures, as well as the under-representation of suburbs. Central cities which had long been underepresented were now losing population to the suburbs and were not greatly affected. Warren's priority on fairness shaped other major decisions. In 1962, over the strong objections of Frankfurter, the Court agreed that questions regarding malapportionment in state legislatures were not political issues, and thus were not outside the Court's purview. For years underpopulated rural areas had deprived metropolitan centers of equal representation in state legislatures. In Warren's California, Los Angeles County had only one state senator. Cities had long since passed their peak, and now it was the middle class suburbs that were underrepresented. Frankfurter insisted that the Court should avoid this "political thicket" and warned that the Court would never be able to find a clear formula to guide lower courts in the rash of lawsuits sure to follow. But Douglas found such a formula: "one man, one vote." In the key apportionment case Reynolds v. Sims (1964) Warren delivered a civics lesson: "To the extent that a citizen's right to vote is debased, he is that much less a citizen," Warren declared. "The weight of a citizen's vote cannot be made to depend on where he lives. This is the clear and strong command of our Constitution's Equal Protection Clause." Unlike the desegregation cases, in this instance, the Court ordered immediate action, and despite loud outcries from rural legislators, Congress failed to reach the two-thirds needed pass a constitutional amendment. The states complied, reapportioned their legislatures quickly and with minimal troubles. Numerous commentators have concluded reapportionment was the Warren Court's great "success" story. Due process and rights of defendants (1963–66) In Gideon v. Wainwright, the Court held that the Sixth Amendment required that all indigent criminal defendants receive publicly funded counsel (Florida law at that time required the assignment of free counsel