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. Section 2. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. 320 lessons. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. 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. [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. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. Find the full text here.. 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. Legislators are elected by voters, not farms or cities or economic interests." 24 chapters | It also insisted that this apportionment be conducted every 10 years. Perhaps most importantly, this case provided the important precedent that courts could intervene in the district schemes of a state if the legislatures reapportionment was not in line with the Equal Protection clause of the Fourteenth Amendment. It went further to state that Legislators represent people, not trees or acres. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. In this case, the context was with regard to State legislatures. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. 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 . 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REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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. Because this was a requirement of the Equal Protection Clause of the 14. 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. [5] In New Hampshire the state constitutions, since January 1776, had always called for the state senate to be apportioned based on taxes paid, rather than on population. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. 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. 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. copyright 2003-2023 Study.com. The issues were: 1. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. The case was decided on June 15, 1964. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. Star Athletica, L.L.C. "[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). 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 was just one of 15 reapportionment cases the Court decided in June of 1964. 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? ThoughtCo. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. I would definitely recommend Study.com to my colleagues. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. All other trademarks and copyrights are the property of their respective owners. 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. 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 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. For the Senate, each county gets two representatives, regardless of size. 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. What is Reynolds v. The constitution also provided for reapportionment to take place following each decennial census. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, 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, English Common Law System: Definition & History, Jeremy Bentham: Biography, Theory & Ethics, Schedule of Drugs: Classification & Examples, What are Zero Tolerance Laws & Policies? The decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. During the same legislative session, lawmakers also adopted the Crawford-Webb Act, a temporary measure that provided for reapportionment in the event that the constitutional amendment was defeated by voters or struck down by the courts. 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. 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. 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. Spitzer, Elianna. To read more about the impact of Reynolds v. Sims click here. 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. It went further to state that Legislators represent people, not trees or acres. These individuals were voters and taxpayers from this locality. 24 chapters | In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. [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. The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. The U.S. Supreme Court granted certiorari. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. 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. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 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. 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. 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. Numerous states had to change their system of representation in the state legislature. The plaintiffs requested a declaration that "establishing the present apportionment of seats in the Alabama Legislature, were unconstitutional under the Alabama and Federal Constitutions, and an injunction against the holding of future elections for legislators until the legislature reapportioned itself in accordance with the State Constitution. 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. are hardly of any less significance for the present and the future. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Any one State does not have such issues. 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. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. 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? 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. Along with Baker v.Carr (1962) and Reynolds v. Sims (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. 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 district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. Creating fair and effective representation is the main goal of legislative reapportionment and, as a result, the Equal Protection Clause guarantees the "opportunity for equal participation by all voters in the election of state legislators.". 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). 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. 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. Reynolds v. Sims (1964) Case Summary. 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. The state argued that federal courts should not interfere in state apportionment. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional.The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. 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. 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. This system failed to take population size into account, leading to huge discrepancies between district . https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). To unlock this lesson you must be a Study.com Member. They were based on rational state policy that took geography into account, according to the state's attorneys. I would definitely recommend Study.com to my colleagues. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Its like a teacher waved a magic wand and did the work for me. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. 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. When the Court applied this rule to Alabama's then-current apportionment, it ruled that their unequal apportionment violated the voters' equal protection rights protection under the 14th Amendment. It should also be superior in practice as well. As we know that federal law is superior to that of the states. 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. 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. 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. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. 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. All of these are characteristics of a professional legislature except meets biannually. 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. Justice Tom C. Clark wrote a concurring opinion. Yet Another Question demonstrating how people so fundamentally misunderstand the United States.