In an opinion by Chief Justice Charles Evans Hughes, the Court unanimously held that the U.S. Constitution did not prohibit Minnesota's governor from vetoing that state's redistricting map.

But economic changes in the early twentieth century resulted in increasing dissatisfaction with Republicans, leading to the formation of the Minnesota Farmer–Labor Party, which included advocates for farmers and members of the organized labor movement.

In the 1930 gubernatorial election, voters for the first time sent a member of the Farmer–Labor Party – Floyd B. Olson – to the governor's mansion, although Republicans continued to control the state legislature.

[3] The Republican-controlled legislature, aiming to ensure that Republicans retained their seats in the House despite growing Farmer–Labor support, passed a heavily gerrymandered map.

[1] Hughes held that since no redistricting plan had been validly enacted, Minnesota was obligated to conduct its upcoming congressional elections at large.

[5] The Court in Colegrove v. Green (1946) referred to the Smiley decision in its ruling on a malapportioned Illinois congressional map: Justices Hugo Black and Wiley Rutledge each cited it to conclude that disputes involving redistricting were justiciable.