The district court had not erred in its finding that neither the Crawford-Webb Act or the 67-member plan could be used as a permanent reapportionment plan, the attorneys argued. Reynolds v. Sims 1964. Prior to the case, numerous state legislative chambers had districts containing unequal populations; for example, in the Nevada Senate, the smallest district had 568 people, while the largest had approximately 127,000 people. Legislative districts may deviate from strict population equality only as necessary to give representation to political subdivisions and provide for compact districts of contiguous territory. Reynolds v. Sims Significance, "legislators Represent People, Not Trees", The Census, Further Readings Appellant R. A. Reynolds Appellee M. O. Sims Appellant's Claim That representation in both houses of state legislatures must be based on population. The Fourteenth Amendment guarantees equal protection under the law. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. To read more about the impact of Reynolds v. Sims click here. Reynolds v. Sims. The Alabama state constitution states that the number of House representatives should be based on the population of each county as determined by the U.S. census. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. The significance of the U.S. Supreme Court decisions in Baker v. Carr and Reynolds v. Sims is that the decisions established that legislatures must be apportioned according to the one-person, one-vote standard. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? [4][5], On August 26, 1961, the plaintiffs in the suit, a group of voters residing in Jefferson County, Alabama, filed suit in the United States District Court for the Middle District of Alabama. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Numerous states had to change their system of representation in the state legislature. Justice John Harlan II wrote a dissenting opinion. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. and its Licensors Simply stated, an individual's right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State. Because the number of representatives for each district remained the same over those 60 years, some voters in the State had a greater voice in government than others. Reynolds, along with several other people who were all residents, taxpayers and voters from Jefferson County in Alabama, filed a suit in Federal District Court challenging the apportionment of the Alabama state legislature. [5][6] Illinois did not redistrict between 1910 and 1955,[7] while Alabama and Tennessee had at the time of Reynolds not redistricted since 1901. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Amendment by weighing some votes higher than another? of Health. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. For the Senate, each county gets two representatives, regardless of size. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . [12] He warned that: [T]he forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. 100% remote. It should also be superior in practice as well. When the Court applied this rule to Alabama's then-current apportionment, it ruled that their unequal apportionment violated the voters' equal protection rights protection under the 14th Amendment. The case was brought by a group of Alabama voters who alleged that the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment to United States Constitution. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. Chappelle v. Greater Baton Rouge Airport Dist. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. California: Summary & Decision, ILTS School Counselor (235): Test Practice and Study Guide, GED Social Studies: Civics & Government, US History, Economics, Geography & World, Introduction to Human Geography: Help and Review, Foundations of Education: Certificate Program, NY Regents Exam - Global History and Geography: Help and Review, NY Regents Exam - Global History and Geography: Tutoring Solution, DSST Foundations of Education: Study Guide & Test Prep, Praxis Core Academic Skills for Educators: Reading (5713) Prep, Praxis Core Academic Skills for Educators - Writing (5723): Study Guide & Practice, English Common Law System: Definition & History, Jeremy Bentham: Biography, Theory & Ethics, Schedule of Drugs: Classification & Examples, What are Zero Tolerance Laws & Policies? The case of Reynolds v. Sims was ruled to be justiciable, which means that the legislative portion of the United States government had already voted on the issue regarding a similar which case, which renders the actual case to be moot, or not matter. He also alleged that by not doing so, the state was denying the voters and residents of his country their full representation under Alabama law, which violated their equal protection rights found in the 14th Amendment. The U.S. Constitution undeniably protects the right to vote. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. Whatever may be thought of this holding as a piece of political ideology -- and even on that score, the political history and practices of this country from its earliest beginnings leave wide room for debate -- I think it demonstrable that the Fourteenth Amendment does not impose this political tenet on the States or authorize this Court to do so. Along with Baker v. Carr (1962) and Wesberry v. Sanders (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies. Jefferson County, with a population of more than 600,000 received seven seats in the Alabama House of Representatives and one seat in the Senate, while Bullock County, with a population of more than 13,000 received two seats in the Alabama House of Representatives and one seat in the Senate. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). However, should an issue be ruled to be justiciable, this means that one branch of the government's jurisdiction is not able to be infringed upon by other branches of government. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. Just because an issue is deemed to be justiciable in the court of law, does not mean that a case is made moot by the act of voting. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Before the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, as a counterbalance to towns and cities. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. All other trademarks and copyrights are the property of their respective owners. Along with Baker v.Carr (1962) and Reynolds v. Sims (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Because this was a requirement of the Equal Protection Clause of the 14. Chief Justice Earl Warren delivered the 8-1 decision. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. Among the more extreme pre-Reynolds disparities[10] claimed by Morris K. Udall: The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. States may have to balance representation based on population with other legislative goals like ensuring minority representation. In order to be considered justiciable, a case must be considered to be more than just political in essence. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. The plaintiffs requested a declaration that "establishing the present apportionment of seats in the Alabama Legislature, were unconstitutional under the Alabama and Federal Constitutions, and an injunction against the holding of future elections for legislators until the legislature reapportioned itself in accordance with the State Constitution. Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Since population growth in the state over the next 60 years was uneven, the plaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level. The 1901 Alabama Constitution provided for a house of representatives comprising no more than 105 members (with an exception provided for new counties, each of which would be entitled to at least one representative). Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Decision of One Person, One Vote Court Case, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. California: Summary & Decision, ILTS School Counselor (235): Test Practice and Study Guide, GED Social Studies: Civics & Government, US History, Economics, Geography & World, Introduction to Human Geography: Help and Review, Foundations of Education: Certificate Program, NY Regents Exam - Global History and Geography: Help and Review, NY Regents Exam - Global History and Geography: Tutoring Solution, DSST Foundations of Education: Study Guide & Test Prep, Praxis Core Academic Skills for Educators: Reading (5713) Prep, Praxis Core Academic Skills for Educators - Writing (5723): Study Guide & Practice, What is a Magnetic Compass? In a majority opinion joined by five other justices, Chief Justice Earl Warren ruled that the Fourteenth Amendment's Equal Protection Clause requires states to establish state legislative electoral districts roughly equal in population. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. The decision had a major impact on state legislatures, as many states had to change their system of representation. 2d 506 (1964), in which the U.S. Supreme Court established the principle of one person, one vote based on the equal protection clause of the Fourteenth Amendment . During the same legislative session, lawmakers also adopted the Crawford-Webb Act, a temporary measure that provided for reapportionment in the event that the constitutional amendment was defeated by voters or struck down by the courts. There must be a causal connection between the injury and the conduct brought before the court. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. Section 1. This inherently nullifies the votes of some citizens and even weighted some more than the other since the distracting scheme did not reflect their population. Equal Protection as guaranteed by the 5th and 14th amendments require broadly that each person be treated equally in their voting power, but what equality means relies on a series of Supreme Court cases. In Reynolds v. Sims, the Court was presented with two issues: The Supreme Court held that the apportionment issue concerning Alabama's legislature was justiciable. The Crawford-Webb Act provided for a 106-member house of representatives (with each of the state's 67 counties having one representative by default and the remaining seats being allocated on the basis of population) and a 35-member state senate (with districts drawn to adhere to existing county lines). Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Baker v. Carr. Oyez. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Yes. Sims: Summary, Decision & Significance. Reynolds v. Sims (1964) Case Summary. Sims?ANSWERA.) Reynolds v. Sims: Supreme Court Case, Arguments, Impact. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. 320 lessons. There are three basic requirements for one to have legal standing in a court case when attempting to file a lawsuit, according to the laws governing the United States of America. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . This system failed to take population size into account, leading to huge discrepancies between district . However, two years before the Reynolds case, in Baker v. Carr (1962), the Supreme Court ruled that a redistricting attempt by the Tennessee legislature was a justiciable issue because the issue dealt with the interpretation of a state law and not their political process. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." All rights reserved. Reynolds v. Sims: Summary, Decision & Significance Instructor: Kenneth Poortvliet Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time. Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabamas legislative apportionment was unconstitutional because it violated the 14th Amendments Equal protection clause of the U.S constitution. The District Courts remedy of temporary reapportionment was appropriate for purposes of the 1962 elections, and it allows for the reapportioned legislature a chance to find a permanent solution for Alabama. Reynolds v. Sims (1964) Summary [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabama's legislative apportionment was unconstitutional because it violated the 14th Amendment's Equal protection clause of the U.S constitution. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Reynolds v. Sims (1964) Case Summary. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. Representatives shall be apportioned among the several States according to their respective numbers, counting the whole number of persons in each State, excluding Indians not taxed. if(document.getElementsByClassName("reference").length==0) if(document.getElementById('Footnotes')!==null) document.getElementById('Footnotes').parentNode.style.display = 'none'; Communications: Alison Graves Carley Allensworth Abigail Campbell Sarah Groat Caitlin Vanden Boom This system failed to take population size into account, leading to huge discrepancies between district . This case essentially set the standard for the notion of one person, one vote and asserted that legislative districts should be apportioned in ways that are very much closely, if not uniform in population. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. The U.S. Supreme Court granted certiorari. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 24 chapters | The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Simply because one of Alabamas apportionment plans resembled the Federal set up of a House comprised of representatives based on population, and a Senate comprised of an equal number of representatives from each State does not mean that such a system is appropriate in a State legislature. Village of Arlington Heights v. Metropolitan Housing Development Corp. Regents of the University of California v. Bakke, Crawford v. Los Angeles Board of Education, Board of Education of Oklahoma City v. Dowell, Northeastern Fla. Chapter, Associated Gen. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. I feel like its a lifeline. This right, can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise.Alabama diluted the vote of some of its residents by failing to offer representation based on population. State representatives represent people, not geographic regions. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. The ruling in Reynolds v. Sims led to the one person, one vote rule, which aids in making sure legislative districts are divided equally so individual voting rights are not violated. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. Create your account. Dilution of a persons vote infringes on his or her right of suffrage. Senator Everett Dirksen of Illinois led a fight to pass a constitutional amendment allowing legislative districts based on land area, similar to the United States Senate. v. Abbott, Governor of Texas. Attorneys representing the voters argued that Alabama had violated a fundamental principle when it failed to reapportion its house and senate for close to 60 years. The constitution also provided for reapportionment to take place following each decennial census. The Court's decision in Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people. Click here to contact us for media inquiries, and please donate here to support our continued expansion. The district court drafted a temporary re-apportionment plan for the 1962 election. Acknowledging the Court's long standing desire to stay away from the political power struggles within the state governments, the Court noted that since its decision in Baker v. Carr, there have been several cases filed across the country regarding the dilution of voters' rights due to inequitable apportionment. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. A citizens vote should not be given more or less weight because they live in a city rather than on a farm, Chief Justice Warren argued. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. Voters from Jefferson County, Alabama challenged the apportionment structure of their State House and Senate, which required each county to have at least one representative, regardless of size. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. 2. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. Sounds fair, right? Post-Reynolds, a number of states had to change their apportionment plans to take population into account. copyright 2003-2023 Study.com. Reynolds believed that, due to the population growth in the county where he lived and what was written in the state constitution of Alabama, there were not enough elected officials acting as representatives for the area. [2], Reynolds v. Sims established that the Equal Protection Clause of the Fourteenth Amendment requires both houses of state legislature to be apportioned based on population.[2]. "[4][5], In July 1962, the state legislature approved a proposed constitutional amendment providing for a 106-member house of representatives (with each of the state's 67 counties having one representative by default and the remaining seats being allocated on the basis of population) and a 67-member state senate (with one senator from each county). Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. Some states refused to engage in regular redistricting, while others enshrined county by county representation (Like the federal government does with state by state representation) in their constitutions. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. These three requirements are as follows: 1. M.O. What case violated the Equal Protection Clause? In this case, the context was with regard to State legislatures. In addition, the majority simply denied the argument that states were permitted to base their apportionment structures upon the Constitution itself, which requires two senators from each state despite substantially unequal populations among the states. Ratio variances as great as 41 to 1 from one senatorial district to another existed in the Alabama Senate (i.e., the number of eligible voters voting for one senator was in one case 41 times the number of voters in another). Furthermore, the existing apportionment, and also, to a lesser extent, the apportionment under the Crawford-Webb Act, presented little more than crazy quilts, completely lacking in rationality, and could be found invalid on that basis alone. The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Create an account to start this course today. Reynolds v. Sims is a 1964 Supreme Court case holding that the Equal Protection Clause of the Fourteenth Amendment requires seats in a state legislature to be apportioned so that one vote equals one person residing in each state legislative district. Justice John Marshall Harlan dissented. The case was named for M. O. Sims, one of the voters who brought the suit, and B. I would definitely recommend Study.com to my colleagues. This ruling was so immediately impactful to state legislatures that there was an attempt to pass a constitutional amendment to allow states to have districts of varying populations. In this case, the context was with regard to State legislatures. We hold that, as a basic constitutional standard, the Equal Protection Clause requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1960/6, http://www.pbs.org/wnet/supremecourt/rights/landmark_reynolds.html, http://law2.umkc.edu/faculty/projects/ftrials/conlaw/ReynoldsvSims.html, Spring 2016: Mosopefoluwa Ojo,Destiny Williams,Everette Hemphill,Trenton Jackson, [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabamas legislative apportionment was unconstitutional because it violated the 14.