Reapportionment has long been a source of political and legal controversy in Hawaii.48 Although the Organic Act required that it be carried out periodically, the territorial legislature failed to observe that mandate, a failure unsuccessfully challenged in Territory v. Tam (1942). A second challenge (Dyer v. Abe, 1956) initially succeeded, but was later dismissed as moot (Dyer v. Abe, 1958) since in the meantime Congress had reapportioned the territorial legislature by amending the Organic Act. This plan followed provisions adopted by the 1950 convention:...
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