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. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. 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. Within two years, the boundaries of legislative districts had been redrawn all across the nation. 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. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. 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. [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. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. Section 1. Justice Tom C. Clark wrote a concurring opinion. These individuals were voters and taxpayers from this locality. Baker v. Carr. Oyez. [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. In Reynolds v. Sims (1964) the U.S. Supreme Court ruled that states must create legislative districts that each have a substantially equal number of voters to comply with the Equal Protection Clause of the Fourteenth Amendment. However, states should strive to create districts that offer representation equal to their population. 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. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. 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. 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. Its like a teacher waved a magic wand and did the work for me. [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]. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. 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. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." 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. The district court drafted a temporary re-apportionment plan for the 1962 election. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. 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. 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. Village of Arlington Heights v. Metropolitan Housing Development Corp. Regents of the University of California v. Bakke, Crawford v. Los Angeles Board of Education, Board of Education of Oklahoma City v. Dowell, Northeastern Fla. Chapter, Associated Gen. The court 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. v. Abbott, Governor of Texas. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. In previous cases, the Supreme Court ruled that any state reapportionment and redistricting disputes were non-justiciable and should be left to state legislatures as purely political questions in which the federal courts should not interfere. For instance, South Carolina had elected one state senator from each county. 100% remote. "[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). Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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. [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. copyright 2003-2023 Study.com. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. 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." 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? These plans were to take effect in time for the 1966 elections. The act was temporary and would only be put in place if the first plan was defeated by voters. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Can a state use a reapportionment plan that ignores significant shifts in population? 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. The district courts judgement was affirmed. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. 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 established the precedent that felons are not allowed to vote.B.) These three requirements are as follows: 1. Requiring states to employ honest and good faith practices when creating districts. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabamas legislative apportionment was unconstitutional because it violated the 14th Amendments Equal protection clause of the U.S constitution. The state argued that federal courts should not interfere in state apportionment. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. 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. 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. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? Numerous states had to change their system of representation in the state legislature. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 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. 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. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. Legislators are elected by voters, not farms or cities or economic interests. On this Wikipedia the language links are at the top of the page across from the article title. States may have to balance representation based on population with other legislative goals like ensuring minority representation. 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. 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. Create your account. 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. State survey of the federal grant review process, State responses to the federal grant review process survey, 2021, State responses by question to the federal grant review process survey, 2021, Federalism by the numbers: Federal mandates, Federalism by the numbers: Federal grants-in-aid, Federalism by the numbers: Federal information collection requests, Overview of federal spending during the coronavirus (COVID-19) pandemic, United States District Court for the Middle District of Alabama, Full text of case syllabus and opinions (Justia), Ballotpedia's Election Administration Legislation Tracker, Election legislation tracking: weekly digest, Election legislation tracking: list of sub-topics, Ken Carbullido, Vice President of Election Product and Technology Strategy, https://ballotpedia.org/wiki/index.php?title=Reynolds_v._Sims&oldid=9027523, Pages using DynamicPageList dplreplace parser function, Federalism court cases, equal protection clause, Federalism court cases, Fourteenth Amendment, Conflicts in school board elections, 2021-2022, Special Congressional elections (2023-2024), 2022 Congressional Competitiveness Report, State Executive Competitiveness Report, 2022, State Legislative Competitiveness Report, 2022, Partisanship in 2022 United States local elections. Prior to the case, numerous state legislative chambers had districts containing unequal populations; for example, in the Nevada Senate, the smallest district had 568 people, while the largest had approximately 127,000 people. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. To unlock this lesson you must be a Study.com Member. 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. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. The Fourteenth Amendment guarantees equal protection under the law. All rights reserved. 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 order to be considered justiciable, a case must be considered to be more than just political in essence. There must be a causal connection between the injury and the conduct brought before the court. 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. This system failed to take population size into account, leading to huge discrepancies between district . Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. 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. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. The state constitution required at least . The ones that constitutional challenges. Reynolds v. Sims. 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." Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. Section 2. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. 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. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Justice John Harlan II wrote a dissenting 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. Chief Justice Earl Warren delivered the opinion of the court. 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. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. Spitzer, Elianna. The Court had already extended "one person, one vote" to all U.S. congressional districts in Wesberry v. Sanders (1964) a month before, but not to the Senate. Sounds fair, right? 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. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Instead, the issues were being left open due to the Court's reluctance to avoid the problem. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. Click here to contact our editorial staff, and click here to report an error. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. 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. After 60 years of significant population growth, some areas of the State had grown in population far more than others. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. In this case, the context was with regard to State legislatures. 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. 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. 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. As we know that federal law is superior to that of the states. 320 lessons. It went further to state that Legislators represent people, not trees or acres. are hardly of any less significance for the present and the future. 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. 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).

Nc American Legion Baseball Standings, Is A House Fire Considered A Natural Disaster, Surfboard Art Australia, What Happened To Frankie Barstool, How To Calculate Heating Value Of Natural Gas?, Articles R