She has also worked at the Superior Court of San Francisco's ACCESS Center. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 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! Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Create your account. Without reapportionment, multiple districts were severely underrepresented. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. 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. Interns wanted: Get paid to help ensure that every voter has unbiased election information. copyright 2003-2023 Study.com. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. 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. M.O. Any one State does not have such issues. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized. [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. The U.S. Constitution undeniably protects the right to vote. The constitution also provided for reapportionment to take place following each decennial census. 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 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. 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 doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. Let's say your county sent five representatives to the state legislature, just like your neighboring county. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. In this case, the context was with regard to State legislatures. This system failed to take population size into account, leading to huge discrepancies between district . The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). 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 . All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. The state argued that federal courts should not interfere in state apportionment. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. What is Reynolds v. 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. 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. 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. They were based on rational state policy that took geography into account, according to the state's attorneys. 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 went further to state that Legislators represent people, not trees or acres. 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 district court drafted a temporary re-apportionment plan for the 1962 election. Create your account. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. 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 district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by 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. 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. These plans were to take effect in time for the 1966 elections. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. "[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). Section 1. 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. It called for a 106-member House and a 35-member Senate. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. Chief Justice Earl Warren delivered the 8-1 decision. Amendment. 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. [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. At the end of July 1962, the district court reached a ruling. copyright 2003-2023 Study.com. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. 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. 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. Definition and Examples, Katzenbach v. Morgan: Supreme Court Case, Arguments, Impact, Browder v. Gayle: Court Case, Arguments, Impact, Obergefell v. Hodges: Supreme Court Case, Arguments, Impacts, Bolling v. Sharpe: Supreme Court Case, Arguments, Impact. Learn about the Supreme Court case, Reynolds v. Sims. Sims?ANSWERA.) The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. All other trademarks and copyrights are the property of their respective owners. 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. 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. Star Athletica, L.L.C. 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. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). 100% remote. 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. State officials appealed, arguing that the existing and proposed reapportionment plans are constitutional, and that the district court lacked the power to order temporary reapportionment. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. 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? Chief Justice Earl Warren delivered the opinion of the court. The Court then turned to the equal protection argument. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. 23. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. 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. Along with Baker v. Carr (1962) and Wesberry v. 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. 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. The ones that constitutional challenges. 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. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. This ruling was so immediately impactful to state legislatures that there was an attempt to pass a constitutional amendment to allow states to have districts of varying populations. To unlock this lesson you must be a Study.com Member. 320 lessons. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Reynolds v. Sims Significance, "legislators Represent People, Not Trees", The Census, Further Readings Appellant R. A. Reynolds Appellee M. O. Sims Appellant's Claim That representation in both houses of state legislatures must be based on population. Because this was a requirement of the Equal Protection Clause of the 14. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. Baker v. Carr. Oyez. Reynolds was a resident of Jefferson County, Alabama. 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. The reason for a non-population-based Federal Senate has more to do with a compromise that allowed for the creation of a national government. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . The reaction to the decision was so strong that a United States senator tried to pass a constitutional amendment that would allow states to draw districts based on geography rather than population. 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. The district courts judgement was affirmed. Even though most of that growth occurred in urban areas. 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Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. 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. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Legislators are elected by voters, not farms or cities or economic interests." 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Acknowledging the Court's long standing desire to stay away from the political power struggles within the state governments, the Court noted that since its decision in Baker v. Carr, there have been several cases filed across the country regarding the dilution of voters' rights due to inequitable apportionment. The 1901 Alabama Constitution provided for a house of representatives comprising no more than 105 members (with an exception provided for new counties, each of which would be entitled to at least one representative). Reynolds v. Sims (1964) Case Summary. This violated his equal protection rights under the 14th Amendment. However, states should strive to create districts that offer representation equal to their population. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. 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. State representatives represent people, not geographic regions. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. Warren held that "legislators represent people, not trees or acres. It was argued that it was unnecessary for the Supreme Court to interfere with how states apportioned their legislative districts, and that the 14th Amendment rights of Alabama voters were not being violated. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. 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. 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. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts.