other counties or parts of counties in the creation of a legislative district. This was overridden under the principle of basing districts on population. Today counties are frequently split among districts in forming Tennessee State Senate districts. "One person, one vote" was first applied as a standard for Congressional districts. State legislatures were supposed to redistrict according to changes in population but many had not for decades. Baker v. Carr and subsequent cases fundamentally changed the nature of political representation in the United States, requiring not just Tennessee but nearly every state to redistrict during the 1960s, often several times. This re-apportionment increased the political power of urban areas with greater population and reduced the influence of more rural areas. After he left the Court, Chief Justice Earl Warren called the Baker v. Carr line of cases the most important in his tenure as Chief Justice. See also List of United States Supreme Court cases, volume 369 Gomillion v. Lightfoot, 364 U.S. 339 (1960), was a landmark decision of the Supreme Court of the United States that found an electoral district with boundaries created to disenfranchise African Americans violated the Fifteenth Amendment. Colegrove v. Green, : Disparities in Congressional districts are non-judiciable. "The remedy for unfairness in districting is to secure State legislatures that will apportion properly, or to invoke the ample powers of Congress." (Illinois). Baker v. Carr, : Overturning Colegrove; Redistricting qualifies as a justiciable question. As summarized in Gray, the decision established that Equal Protection "...limits the authority of a State Legislature in designing the geographical districts from which representatives are chosen either for the State Legislature or for the Federal House of Representatives." (Tennessee). Subsequent Cases Regarding Size/Proportionality: Gray v. Sanders, : "One person, one vote." Statewide elections (US Senator, Governor, etc.) must not employ a geographical-unit system that renders some votes greater than others because it "violates the Equal Protection Clause of the Fourteenth Amendment" and that "...once a geographical unit for which a representative is to be chosen is designated, all who participate in the election must have an equal vote..." (Georgia). Wesberry v. Sanders, : Districts for United States House of Representatives must be approximately equal in population as established by Article 1, Section 2 of the Constitution. (Georgia). Reynolds v. Sims, : Districts for State Legislatures (both chambers) must be approximately equal in population as established by Equal Protection. (Alabama). Gaffney v.