The court used the Fourteenth Amendment to the United States Constitution to justify its ruling (specifically the Equal Protection Clause).

[1] The act was enacted by Congress in 1967 primarily due to two reasons: the fear that the courts would force elections to be conducted at large if congressional districts were not compliant with federal jurisprudence or law and that southern states may have dissolved their districts so that racial minorities would not be able to elect representatives that are from a minority race, particularly after the enactment of the Voting Rights Act of 1965.

"[1] However, there were members of Congress opposed to this exemption, with Senator Roman Hruska of Nebraska arguing that "The proposal before us will apply to every State in the Union except two.

Due to the widespread support of the members of Congress that there was a pressing need to ban elections at large, both the House and the Senate passed the bill with a voice vote, although the bill did allow for Hawaii and New Mexico to elect their representatives from single-member districts two years later than all other states due to their need to draw congressional districts for the first time in their histories.

By contrast, constituencies in countries that regularly have more than two candidates on the ballot (such as Canada or the United Kingdom) tend to only be won by a plurality, not a majority.

FPTP, as a result, may be interpreted to be inherently less representative than other election processes, such as mixed-member proportional representation, which is in use in Germany and New Zealand.