In 1961, M.O. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. [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]. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. Amendment. Other articles where Reynolds v. Sims is discussed: Baker v. Carr: precedent, the court held in Reynolds v. Sims (1964) that both houses of bicameral legislatures had to be apportioned according to population. Numerous states had to change their system of representation in the state legislature. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. 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. In an 8-to-1 ruling, it was found that the case of Reynolds v. Sims was justiciable, or had standing, because it was not purely of political concern. To unlock this lesson you must be a Study.com Member. The constitution established a state senate comprising no more than 35 members, with the actual number of senators falling between one-fourth and one-third of the number of state representatives. 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. 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. v. Abbott, Governor of Texas. The decision of this case led to the adoption of the one person, one vote principle, which is a rule that is applied to make sure that legislative districts are zoned so that they are closer to equal in population, in accordance with when the census is taken every ten years. The constitution required that no county be divided between two senatorial districts and that no district comprise two or more counties not contiguous to one another. 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. 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. 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. 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. There must be a causal connection between the injury and the conduct brought before the court. Spitzer, Elianna. Wesberry v. Sanders. Oyez. of Health. 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. Since under neither the existing apportionment provisions nor either of the proposed plans was either of the houses of the Alabama Legislature apportioned on a population basis, the District Court correctly held that all three of these schemes were constitutionally invalid. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. The act was temporary and would only be put in place if the first plan was defeated by voters. 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. To unlock this lesson you must be a Study.com Member. 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. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. [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. As a result of the decision, almost every state had to redraw its legislative districts, and power . 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). Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. I feel like its a lifeline. Justice John Marshall Harlan dissented. 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. For the Senate, each county gets two representatives, regardless of size. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. 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. The case was brought by a group of Alabama voter s who alleged that the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment to United States Constitution. 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. In order to be considered justiciable, a case must be considered to be more than just political in essence. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Create an account to start this course today. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. 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. Click here to contact us for media inquiries, and please donate here to support our continued expansion. Reynolds alleged that Jefferson County had grown considerably while other counties around it hadn't, which created an unequal apportionment since Jefferson County had the same number of representatives as the other counties. [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. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. All rights reserved. 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. 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. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). This is the issue the Supreme Court faced in Reynolds v. Sims (1964). The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. Baker v. are hardly of any less significance for the present and the future. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14th Amendment by weighing some votes higher than another? Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. State senate districts must have roughly equal populations based on the principle of "one person, one vote". The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. [2] Of the forty-eight states then in the Union, only seven[a] twice redistricted even one chamber of their legislature following both the 1930 and the 1940 Censuses. All Rights Reserved Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings, Copyright 2023 Web Solutions LLC. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. Reynolds v. Sims, 377 U.S. 533 (1964), was a landmark United States Supreme Court case in which the Court ruled that the electoral districts of state legislative chambers must be roughly equal in population. Sims?ANSWERA.) QUESTIONWhat was the significance of the famous case Reynolds v. 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. Reynolds was a resident of Jefferson County, Alabama. To read more about the impact of Reynolds v. Sims click here. 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 violated his equal protection rights under the 14th Amendment. 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). 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. It went further to state that Legislators represent people, not trees or acres. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. 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. 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. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. Requiring states to employ honest and good faith practices when creating districts. A causal connection can be drawn from the injury to another source, 3. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. That is, equal protection under the Fourteenth Amendment--which only applies to the states--guarantees that each citizen shall have equal weight in determining the outcome of state elections. Reynolds v. Sims. What amendment did Reynolds v Sims violate? The state appealed the decision to the Supreme Court. The dissent strongly accused the Court of repeatedly amending the Constitution through its opinions, rather than waiting for the lawful amendment process: "the Court's action now bringing them (state legislative apportionments) within the purview of the Fourteenth Amendment amounts to nothing less than an exercise of the amending power by this Court." Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. 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. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Create your account. This system failed to take population size into account, leading to huge discrepancies between district . This system failed to take population size into account, leading to huge discrepancies between district . Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. Legislators are elected by voters, not farms or cities or economic interests." 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. Justice John Harlan II wrote a dissenting opinion. 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? And in deciding the dispute, the Court applied the one-person one-vote rule, therefore holding that the districts were not equal in population size and should be reapportioned to ensure equal representation. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. 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." In this case, the context was with regard to State legislatures. 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. 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. 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. 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. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. The district court drafted a temporary re-apportionment plan for the 1962 election. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. It went further to state that Legislators represent people, not trees or acres. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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 decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. Section 1. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. The issues were: 1. It called for a 106-member House and a 35-member Senate. 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. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. 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. Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court ruled to correct what it considered egregious examples of malapportionment; these were serious enough to undermine the premises underlying republican government. No. 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. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Apply today! The rules of the House are a purely political matter, and it would be unlikely that any ruling from the Supreme Court would settle the question. 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. Only the Amendment process can do that. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. 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. Before a person can bring a suit against their government, he or she must have standing, which requires that: Once a person has standing, then the issue must be justiciable, which means that the issue before the court is not one of a purely political nature. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. Chappelle v. Greater Baton Rouge Airport Dist. 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. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. After 60 years of significant population growth, some areas of the State had grown in population far more than others. 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. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. Within two years, the boundaries of legislative districts had been redrawn all across the nation. They were based on rational state policy that took geography into account, according to the state's attorneys. She also has a Bachelor's of Science in Biological Sciences from California University. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . In Reynolds v. United States, 98 U.S. 145 (1879), the Supreme Court ruled unanimously that a federal law prohibiting polygamy did not violate the free exercise clause of the First Amendment. If they were, the 6 million citizens of the Chicago area would hold sway in the Illinois Legislature without consideration of the problems of their 4 million fellows who are scattered in 100 other counties. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. All other trademarks and copyrights are the property of their respective owners. and its Licensors The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. 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. 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. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. Because this was a requirement of the Equal Protection Clause of the 14. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. It was also believed that the 14th Amendment rights of citizens were being violated due to the lack of apportioned representatives for each of the legislative districts. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. [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.
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