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. They were based on rational state policy that took geography into account, according to the state's attorneys. 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." Without reapportionment, multiple districts were severely underrepresented. The ones that constitutional challenges. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 2. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . 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 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. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. 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. O'Gorman & Young, Inc. v. Hartford Fire Insurance Co. Dobbs v. Jackson Women's Health Organization, Planned Parenthood of Central Missouri v. Danforth, City of Akron v. Akron Center for Reproductive Health, Thornburgh v. American College of Obstetricians & Gynecologists, Ohio v. Akron Center for Reproductive Health, Ayotte v. Planned Parenthood of Northern New England. No. 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 was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. In Reynolds v. Sims (1964), using the Supreme Court's precedent set in Baker v.Carr (1962), Warren held that representation in state legislatures must be apportioned equally on the basis of population rather than geographical areas, remarking that "legislators represent people, not acres or trees." In Miranda v. Arizona (1966)a landmark decision of the Warren court's rulings on . [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Amendments Equal protection clause of the U.S constitution. 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. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. 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. The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. Warren held that "legislators represent people, not trees or acres. Any one State does not have such issues. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. Within two years, the boundaries of legislative districts had been redrawn all across the nation. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Along with Baker v. Carr (1962) and Wesberry v. 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. It is known as the "one person, one vote" case. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. The U.S. Supreme Court granted certiorari. This case overturned a previous ruling or rulings, These being New Jersey, Massachusetts, New Hampshire (, Alabama Legislative Black Caucus v. Alabama, List of United States Supreme Court cases, volume 377, "The Best Supreme Court Decisions Since 1960", "Reapportionments of State Legislatures: Legal Requirement", "B. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. [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]. 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 state constitution of Alabama mandated that, every ten years, populations of all the legislative districts in the state should be examined and appropriate representation, considering population, should be assigned to each of the legislative districts statewide, in accordance with the census that is taken once per decade. 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. Reynolds v. Sims (1964) Case Summary. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. On this Wikipedia the language links are at the top of the page across from the article title. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. [4][5], On July 21, 1962, the district court found that Alabama's existing apportionment system violated the Equal Protection Clause of the Amendment XIV, United States Constitution. Reynolds was a resident of Jefferson County, Alabama. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. 320 lessons. Yes. [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]. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Sims. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Its like a teacher waved a magic wand and did the work for me. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. Let's say your county sent five representatives to the state legislature, just like your neighboring county. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Create your account. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. are hardly of any less significance for the present and the future. 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. 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 district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5], Oral argument was held on November 13, 1963. 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. 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. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. In July 1962, the United States District Court for the Middle District of Alabama acknowledged the changes in Alabamas population and noted that the state legislature could legally reapportion seats based on population, as was required under Alabamas state constitution. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. 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. Chief Justice Earl Warren delivered the opinion of the court. 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. After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. 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. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. 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. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. In Reynolds v. Sims (1964), the Court ruled that the issue presented to them was justiciable, which meant that Reynolds had standing and it was an issue that was not a purely political question. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. 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. 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. The constitution also provided for reapportionment to take place following each decennial census. 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. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). All Rights Reserved 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. The state argued that federal courts should not interfere in state apportionment. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. A likely (not speculative) injury was suffered by an individual, 2. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Sounds fair, right? 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 . Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. Spitzer, Elianna. Requiring states to employ honest and good faith practices when creating districts. 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. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Only the Amendment process can do that. 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. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Create your account. 320 lessons. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. Chappelle v. Greater Baton Rouge Airport Dist. 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 v. Sims is famous for, and has enshrined, the one person, one vote principle. These plans were to take effect in time for the 1966 elections. As a result of the decision, almost every state had to redraw its legislative districts, and power . 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. As we know that federal law is superior to that of the states. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. - 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.''. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. We are advised that States can rationally consider . 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. This meant the rule could be settled by the Supreme Court with some certainty. Within two years, the boundaries of legislative districts had been redrawn all across the nation. The state appealed the decision to the Supreme Court. She also has a Bachelor's of Science in Biological Sciences from California University. v. Abbott, Governor of Texas. The Court then turned to the equal protection argument. Reynolds was sentenced for polygamy Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. The issues were: 1. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. It devised a reapportionment plan and passed an amendment providing for home rule to counties. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. It should also be superior in practice as well. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? It went further to state that Legislators represent people, not trees or acres. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. 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. Reynolds v. Sims 1964. 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. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Wesberry v. Sanders. Oyez. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. Terms of Use, Reynolds v. Sims - "legislators Represent People, Not Trees", Law Library - American Law and Legal Information, Notable Trials and Court Cases - 1963 to 1972, Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings. 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. Requiring states to employ honest and good faith practices when creating districts. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. 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? Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? What case violated the Equal Protection Clause? Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." 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 question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. The district court drafted a temporary re-apportionment plan for the 1962 election. The Court will look to see if all voting districts are fairly equal in population, and if not the Court will order that the state legislature adjust them to make them more equal. 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." Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? 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.