Felix Frankfurter was not merely phrasemaking in 1946 when he warned the Supreme Court to shun the "political thicket" of state legislative apportionment. The court plunged in anywaywith last year's historic one-man, one-vote ruleand ever since, the political thicket has echoed with muffled blows, groans, and cries for divine guidance. Now lower courts are fighting not only state legislatures but one another. In New York last week, two of them battled bench to bench in a grinding collision between federal and state power.
New York's federal courts have long recoiled from meddling with the state's...