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. ThoughtCo. Legislators are elected by voters, not farms or cities or economic interests. 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. 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. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 320 lessons. Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, League of United Latin American Citizens v. Perry, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. The Equal Protection Clause, which was upheld by the ruling in Reynolds v. Sims, states that all legislative districts of individual states should be uniform in population size. In dissent, Justice John Marshall Harlan II wrote that the majority had chosen to ignore the language, history, and original intent of the Equal Protection Clause, which did not extend to voting rights. Reynolds v. Sims | Encyclopedia.com 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. 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. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. 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. 24 chapters | Supreme Court Overturning Reynolds v. Sims: Chances - reddit 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. 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. Reynolds v. Sims - Significance - Court, Districts, Alabama, and --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. State legislatures had been reluctant to redistrict[2] because there existed general upper-class fear that if redistricting to meet population changes were carried out, voters in large, expanding or expanded urban areas would vote for confiscatory wealth redistribution[3] that would severely inhibit the power of business interests who controlled state and city governments[4] early in the century. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Let's say your county sent five representatives to the state legislature, just like your neighboring county. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? These three requirements are as follows: 1. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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). Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Quiz & Worksheet - Reynolds v. Sims 1964 | Study.com 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. This system failed to take population size into account, leading to huge discrepancies between district . Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. To determine if an issue is justiciable, the Court will look at the nature of the issue, and if it is one dealing with the political power of either the executive or legislative branches, and if it is unlikely that a ruling by the courts will settle the issue, then is it a political question and is non-justiciable. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. 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 Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. The second plan was called the Crawford-Webb Act. 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. 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. Voters in the states are represented by members of their state legislature. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. As a result, virtually every state legislature was . http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. And the right of suffrage 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. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. It established the precedent that felons are not allowed to vote.B.) The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. Star Athletica, L.L.C. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). 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). 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. It was argued that it was unnecessary for the Supreme Court to interfere with how states apportioned their legislative districts, and that the 14th Amendment rights of Alabama voters were not being violated. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). The districts adhered to existing county lines. 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. 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. The only vote cast not in favor of Reynolds was from Associate Justice John Marshall Harlan II, whose dissenting opinion was that the Equal Protection Clause of the 14th Amendment was not applicable when it came to voting rights. Sounds fair, right? Spitzer, Elianna. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. Research: Josh Altic Vojsava Ramaj The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. The case was named for M. O. Sims, one of the voters who brought the suit, and B. 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. Justices for the Court: Hugo L. Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Chief Justice Earl Warren, Byron R. White. (2020, August 28). 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. - Definition, Reintegrative Shaming: Definition & Theory in Criminology, Victimology: Contemporary Trends & Issues, Law Enforcement & Crime Victims: Training & Treatment, Practical Application: Measuring the Extent of Victimization, Personal Crimes: Types, Motivations & Effects, Explanations for Personal Crimes: Victim Precipitation & Situated Transactions, Impacts of Personal Crimes on Direct & Indirect Victims, Working Scholars Bringing Tuition-Free College to the Community, The plaintiff must have suffered an ''injury in fact.''. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . The case was decided on June 15, 1964. 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. To unlock this lesson you must be a Study.com Member. 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. Today's holding is that the Equal Protection Clause of the Fourteenth Amendment requires every State to structure its legislature so that all the members of each house represent substantially the same number of people; other factors may be given play only to the extent that they do not significantly encroach on this basic 'population' principle. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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). 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. State representatives represent people, not geographic regions. The district court drafted a temporary re-apportionment plan for the 1962 election. 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. and its Licensors 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. Thus his vote was diluted in value because the group of representatives from his state had no more influence than a county with half the population. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. 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 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. 23. 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. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. 100% remote. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. These individuals were voters and taxpayers from this locality. What was the significance of the famous case Reynolds v. Sims? Yes. States may have to balance representation based on population with other legislative goals like ensuring minority representation. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). It is known as the "one person, one vote" case. Justice John Harlan II wrote a dissenting opinion. Create your account. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. 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. 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? Learn about the Supreme Court case, Reynolds v. Sims. What was the significance of Reynolds vs Sims? - WittyQuestion.com States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. Sims: Summary, Decision & Significance. 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. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. In this case, the context was with regard to State legislatures. 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. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. What case violated the Equal Protection Clause? The District Court was correct to come to that holding and to reject the States proposed apportionment plans. What resulted from the supreme court decisions in Baker v. Carr. 24 chapters | It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. External Relations: Moira Delaney Hannah Nelson Caroline Presnell The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas.