Mullane v. Central Hanover Bank & Trust Co. Cleveland Board of Education v. Loudermill, Cruzan v. Director, Missouri Department of Health, Cumming v. Richmond County Board of Education, Sipuel v. Board of Regents of the University of Oklahoma, Davis v. County School Board of Prince Edward County, Griffin v. County School Board of Prince Edward County, Green v. County School Board of New Kent County, United States v. Montgomery County Board of Education, Alexander v. Holmes County Board of Education, Swann v. Charlotte-Mecklenburg Board of Education. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. 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. Its like a teacher waved a magic wand and did the work for me. Reynolds believed that, due to the population growth in the county where he lived and what was. Definition and Examples, Katzenbach v. Morgan: Supreme Court Case, Arguments, Impact, Browder v. Gayle: Court Case, Arguments, Impact, Obergefell v. Hodges: Supreme Court Case, Arguments, Impacts, Bolling v. Sharpe: Supreme Court Case, Arguments, Impact. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. Reynolds was sentenced for polygamy 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. The court held that Once the geographical boundaries of a district are set, all who participate in that election have an equal vote no matter their sex, race, occupation, or geographical unit. As mentioned earlier in this lesson, the one person, one vote clause is applicable to the Equal Protection Clause because it was ruled that voting is a protected right of the citizens of Alabama, and all other states. The reaction to the decision was so strong that a United States senator tried to pass a constitutional amendment that would allow states to draw districts based on geography rather than population. Voters in the states are represented by members of their state legislature. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? The 1962 Alabama general election was conducted on the basis of the court-ordered plan, which was immediately appealed to the U.S. Supreme Court. Reynolds claimed that as his county gained in population and others around it remained stagnant, each representative to the state legislature represented more voters in Jefferson County then a neighboring county. Requiring states to employ honest and good faith practices when creating districts. 24 chapters | 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. Can a state use a reapportionment plan that ignores significant shifts in population? By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. All rights reserved. It is known as the "one person, one vote" case. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. [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]. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Numerous states had to change their system of representation in the state legislature. 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. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. [13], In a 2015 Time Magazine survey of over 50 law professors, both Erwin Chemerinsky (Dean, UC Berkeley School of Law) and Richard Pildes (NYU School of Law) named Reynolds v. Sims the "best Supreme Court decision since 1960", with Chemerinsky noting that in his opinion, the decision made American government "far more democratic and representative."[1]. The case of Reynolds v. Sims was initially argued November 13, 1963, but a decision on this case was not reached until June 15, 1964. 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. 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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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). The court also ruled in Wesberry v. Sanders that when votes weigh more in one district than another, the idea of a representative democracy is undermined. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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. copyright 2003-2023 Study.com. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. I feel like its a lifeline. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Reynolds v. Sims is a well-known court case which made its way through district courts and ended up being heard by the United States Supreme Court. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Yes. v. Abbott, Governor of Texas. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. A likely (not speculative) injury was suffered by an individual, 2. 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. 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. 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. 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. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. 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. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 1, Schuette v. Coalition to Defend Affirmative Action, Students for Fair Admissions v. President and Fellows of Harvard College, Personnel Administrator of Massachusetts v. Feeney, Mississippi University for Women v. Hogan. This is called the political question doctrine, and is invoked if the issue is such that a hearing by the courts will not settle the issue due to its purely political nature. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. However, states should strive to create districts that offer representation equal to their population. The decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. The case of Reynolds v. Sims arose after voters in Birmingham, Alabama, challenged the apportionment of the Alabama Legislature; the Constitution of Alabama provided for one state senator per county regardless of population differences. Legislators are elected by voters, not farms or cities or economic interests. Justice Potter Stewart also issued a concurring opinion, in which he argued that while many of the schemes of representation before the court in the case were egregiously undemocratic and clearly violative of equal protection, it was not for the Court to provide any guideline beyond general reasonableness for apportionment of districts. The case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. The constitution also provided for reapportionment to take place following each decennial census. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. Reynolds v. Sims 1964. I feel like its a lifeline. and its Licensors 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. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Without reapportionment, multiple districts were severely underrepresented. The state appealed the decision to the Supreme Court. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. It went further to state that Legislators represent people, not trees or acres. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. City of Cleburne v. Cleburne Living Center, Inc. Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank, Board of Trustees of the University of Alabama v. Garrett, Nevada Department of Human Resources v. Hibbs, https://en.wikipedia.org/w/index.php?title=Reynolds_v._Sims&oldid=1142377374, United States electoral redistricting case law, United States One Person, One Vote Legal Doctrine, American Civil Liberties Union litigation, United States Supreme Court cases of the Warren Court, Creative Commons Attribution-ShareAlike License 3.0, Appeal from the United States District Court for the Middle District of Alabama. The U.S. Supreme Court affirmed the district court, holding that the, The District Court for the Middle District of Alabama found that the reapportionment plans proposed by the Alabama Legislature would not cure the. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. Justice John Harlan II wrote a dissenting opinion. The reason for a non-population-based Federal Senate has more to do with a compromise that allowed for the creation of a national government. Reynolds v. Sims (1964) Case Summary. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. As we know that federal law is superior to that of the states. The district court drafted a temporary re-apportionment plan for the 1962 election. On this Wikipedia the language links are at the top of the page across from the article title. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. The plaintiffs further argued that "since population growth in the state from 1900 to 1960 had been uneven, Jefferson and other counties were now victims of serious discrimination with respect to the allocation of legislative representation" (i.e., population variations between districts created situations in which the voters of a smaller district were entitled to the same representation in the legislature as the voters of larger districts; each district). "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." But when the right to vote at any election for the choice of electors for President and Vice-President of the United States, Representatives in Congress, the Executive and Judicial officers of a State, or the members of the Legislature thereof, is denied to any of the male inhabitants of such State, being twenty-one years of age, and citizens of the United States, or in any way abridged, except for participation in rebellion, or other crime, the basis of representation therein shall be reduced in the proportion which the number of such male citizens shall bear to the whole number of male citizens twenty-one years of age in such State. In another case, Wesberry v. Sanders, the Court applied the one person, one vote principle to federal districts for electing members of the House of Representatives. Reynolds v. Sims. It is of the essence of a democratic society, Chief Justice Warren wrote. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. I would definitely recommend Study.com to my colleagues. 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. Along with Baker v. Carr (1962) and Wesberry v. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances? Dilution of a persons vote infringes on his or her right of suffrage. 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. Sims?ANSWERA.) M.O. In 1961, M.O. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized. Requiring states to employ honest and good faith practices when creating districts. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. The second plan was called the Crawford-Webb Act. But when the right to vote at any election for the choice of electors for President and Vice-President of the United States, Representatives in Congress, the Executive and Judicial officers of a State, or the members of the Legislature thereof, is denied to any of the male inhabitants of such State, being twenty-one years of age, and citizens of the United States, or in any way abridged, except for participation in rebellion, or other crime, the basis of representation therein shall be reduced in the proportion which the number of such male citizens shall bear to the whole number of male citizens twenty-one years of age in such State. In the case of Baker v. Carr, the court heard the argument for whether or not the Supreme Court had the right to redistrict legislative offices considering population changes in legislative districts. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. Create an account to start this course today. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. State officials appealed, arguing that Alabamas existing and proposed reapportionment plans are constitutional and that the District Court lacked the power to reapportion the Legislature itself. It called for a 106-member House and a 35-member Senate. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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). Any one State does not have such issues. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. In this case, the context was with regard to State legislatures. Only the Amendment process can do that. 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. Chappelle v. Greater Baton Rouge Airport Dist. State representatives represent people, not geographic regions. Create your account. 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. "[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). Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. Enrolling in a course lets you earn progress by passing quizzes and exams. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. 23. 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. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. In the landmark case of Reynolds v. Sims, which concerned representation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among the several states according to their respective numbers." ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. 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 significance of this case is related to the Equal Protection Clause of the 14th Amendment, which states that state governments must treat their individuals fairly, and not differently, according to the law. 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. 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 Equal Protection Clause of the 14th Amendment mandates that individual states work to provide equal protection, which means that governing occurs without bias and that lone individual differences are unimportant when considering citizens. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al", "Reapportionment--I "One Man, One Vote" That's All She Wrote! Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional.The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. This system failed to take population size into account, leading to huge discrepancies between district . He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. However, allegations of State Senates being redundant arose, as all states affected retained their state senates, with state senators being elected from single-member districts, rather than abolishing the upper houses, as had been done in 1936 in Nebraska[b] (and in the provinces of Canada), or switching to electing state senators by proportional representation from several large multi-member districts or from one statewide at-large district, as was done in Australia. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. 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.