The Equal Protection Clause of the 14th Amendment mandates that individual states work to provide equal protection, which means that governing occurs without bias and that lone individual differences are unimportant when considering citizens. Create your account. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. 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. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. Reynolds believed that, due to the population growth in the county where he lived and what was. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. They were based on rational state policy that took geography into account, according to the state's attorneys. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. This system failed to take population size into account, leading to huge discrepancies between district . It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. It devised a reapportionment plan and passed an amendment providing for home rule to counties. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." 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. 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." The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. The political question doctrine states that, when it is invoked, that a case is unable to be settled in the court of law if the issue it addresses stems from an essence that is merely political in its nature. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. For the Senate, each county gets two representatives, regardless of size. v. Abbott, Governor of Texas. 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. This right, 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.Alabama diluted the vote of some of its residents by failing to offer representation based on population. Its like a teacher waved a magic wand and did the work for me. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Sims: Summary, Decision & Significance. 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. [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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Along with Baker v. Carr (1962) and Wesberry v. All rights reserved. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Shortly after the Supreme Court handed down its decision in Baker v. Carr in March of 1962, under pressure from the federal district court that was still considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. 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 . Reynolds v. Sims (1964) Case Summary. 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. 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. 2. Section 2. At the end of July 1962, the district court reached a ruling. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Just because an issue is deemed to be justiciable in the court of law, does not mean that a case is made moot by the act of voting. The state argued that federal courts should not interfere in state apportionment. 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. As we know that federal law is superior to that of the states. It should also be superior in practice as well. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al", "Reapportionment--I "One Man, One Vote" That's All She Wrote! 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. After 60 years of significant population growth, some areas of the State had grown in population far more than others. 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." Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Enrolling in a course lets you earn progress by passing quizzes and exams. copyright 2003-2023 Study.com. [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]. Without reapportionment, multiple districts were severely underrepresented. Yes. 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. 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. The ones that constitutional challenges. This violated his equal protection rights under the 14th Amendment. Legislators are elected by voters, not farms or cities or economic interests." 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 . Star Athletica, L.L.C. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. I feel like its a lifeline. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Sims. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. 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. External Relations: Moira Delaney Hannah Nelson Caroline Presnell Reynolds v. Sims (1964) Case Summary. 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. Sims?ANSWERA.) However, states should strive to create districts that offer representation equal to their population. Spitzer, Elianna. In 2016, the Supreme Court rejected a challenge to "one person, one vote" in Evenwel et al. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. [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. 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. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Legislators are elected by voters, not farms or cities or economic interests." 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. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Reynolds v. Sims 1964. 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. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. 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. 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 constitution also provided for reapportionment to take place following each decennial census. 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. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. These three requirements are as follows: 1. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. I would definitely recommend Study.com to my colleagues. 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. Only the Amendment process can do that. Create an account to start this course today. 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. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Before Reynolds, urban counties nationwide often had total representations similar to rural counties, and in Florida, there was a limit to three representatives even for the most populous counties. 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. This system failed to take population size into account, leading to huge discrepancies between district . 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. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. It is of the essence of a democratic society, Chief Justice Warren wrote. [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. What is Reynolds v. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. 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. 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. Because of this principle, proper proportioning of representatives should exist in all legislative districts, to make sure that votes are about equal with the population of residents. 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. Requiring states to employ honest and good faith practices when creating districts. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Wesberry v. Sanders. Oyez. 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. 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). To unlock this lesson you must be a Study.com Member. 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. - 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.''. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. A causal connection can be drawn from the injury to another source, 3. The decision had a major impact on state legislatures, as many states had to change their system of representation. 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. 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. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. 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. 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. 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. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. 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. She has also worked at the Superior Court of San Francisco's ACCESS Center. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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. Argued November 13, 1963. Numerous states had to change their system of representation in the state legislature. 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 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. 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. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. 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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. It gave . Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. 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? When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. 24 chapters | 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 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. of Health. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. Legislators are elected by voters, not farms or cities or economic interests. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). "[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 state appealed the decision to the Supreme Court. 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. 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. 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 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. 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. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. 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 case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. The Court then turned to the equal protection argument. The Alabama Constitution provided that there be only one state senator per county. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. Even though most of that growth occurred in urban areas. Voters in the states are represented by members of their state legislature. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. State representatives represent people, not geographic regions. Equal Protection as guaranteed by the 5th and 14th amendments require broadly that each person be treated equally in their voting power, but what equality means relies on a series of Supreme Court cases.