In "Reynolds v. Sims" (1963), the chief justice wrote what biographer Ed Cray terms "the most influential of the 170 majority opinions would write." While eight of the nine justices had voted to require congressional districts of equal population in "Wesberry", some of the justices were reluctant to require state legislative districts to be of equal population. Warren indicated that the Equal Protection Clause required that state legislative districts be apportioned on an equal basis: "legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests." His holding upheld the principle of "one man, one vote," which had previously been articulated by Douglas. After the decision, the states reapportioned their legislatures quickly and with minimal troubles. Numerous commentators have concluded reapportionment was the Warren Court's great "success story."