the historical underpinnings of these rulings can be traced to the debates at the constitutional convention of 1787. as the court in wesberry recounted, the framers of the constitution were determined to create a system in which the house of representatives would reflect population, as delegates like james madison and george mason argued against "vicious representation" akin to the rotten boroughs of great britain. see wesberry, 376 u.s. at 12-13. these "rotten boroughs," where sparsely populated districts held disproportionate political power, were a warning to the framers of the dangers of unbalanced representation. madison himself described the english system as flawed, noting that the small borough of old sarum, with few inhabitants, could send two members to parliament while the populous city of london had only four. id. at 14. while equal representation is a vital component of a democratic system, the states role in preserving the integrity of elections has also been a key area of supreme court jurisprudence. in eu v. san francisco county democratic central committee, 489 u.s. 214 (1989), the court held that a state has a "compelling interest in preserving the integrity of its election process." id. at 231. confidence in the integrity of elections, the court explained, is essential for the functioning of democracy, as voter fraud can disenfranchise legitimate voters and breed distrust in government. similarly, in purcell v. gonzalez, 549 u.s. 1 (2006), the court reiterated that concerns over electoral fraud could justify certain regulations, even if they impose some burdens on the right to vote, as long as they are justified by a legitimate state interest. id. at 4.
United States