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. Chief Justice Earl Warren delivered the opinion of the court. 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 U.S. Supreme Court granted certiorari. 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. 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. 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 Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Reynolds was a resident of Jefferson County, Alabama. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Reynolds v. Sims, 377 U.S. 533 (1964) - Justia Law 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. 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. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. 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. - 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.''. The U.S. Constitution undeniably protects the right to vote. Reynolds v. Sims - Significance - Court, Districts, Alabama, and No. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. To unlock this lesson you must be a Study.com Member. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. 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. Reynolds v. Sims | Teaching American History 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. 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 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. (2020, August 28). 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 response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. Reynolds v. Sims | Oyez - {{meta.fullTitle}} The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Reynolds, along with several other people who were all residents, taxpayers and voters from Jefferson County in Alabama, filed a suit in Federal District Court challenging the apportionment of the Alabama state legislature. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Legislators are elected by voters, not farms or cities or economic interests. However, states should strive to create districts that offer representation equal to their population. Sims?ANSWERA.) The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. It gave . This system failed to take population size into account, leading to huge discrepancies between district . Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . It devised a reapportionment plan and passed an amendment providing for home rule to counties. Reynolds v. Sims - Ballotpedia Reynolds v. Sims - Significance, "legislators Represent People, Not The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. 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. 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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. 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 district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. [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. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. Enrolling in a course lets you earn progress by passing quizzes and exams. Jefferson County, with a population of more than 600,000 received seven seats in the Alabama House of Representatives and one seat in the Senate, while Bullock County, with a population of more than 13,000 received two seats in the Alabama House of Representatives and one seat in the Senate. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch 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. Learn about the Supreme Court case, Reynolds v. Sims. Reynolds v. Sims (1964) - Rose Institute The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 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Chief Justice Earl Warren delivered the 8-1 decision. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. 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. 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. The Alabama Constitution provided that there be only one state senator per county. 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 case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. Spitzer, Elianna. 320 lessons. 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. 2. State representatives represent people, not geographic regions. 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. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. To read more about the impact of Reynolds v. Sims click here. It went further to state that Legislators represent people, not trees or acres. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. A causal connection can be drawn from the injury to another source, 3. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. The state constitution required at least . Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell 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. Sims. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. 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. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? v. Abbott, Governor of Texas. Reynolds v. Sims | Encyclopedia.com 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. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. 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 next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Only the Amendment process can do that. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. Numerous states had to change their system of representation in the state legislature. 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. 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. Baker v. Carr: Supreme Court Case, Arguments, Impact, The Civil Rights Act of 1866: History and Impact, Shaw v. Reno: Supreme Court Case, Arguments, Impact, What Is A Poll Tax? The constitution established a state senate comprising no more than 35 members, with the actual number of senators falling between one-fourth and one-third of the number of state representatives. 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. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. 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. 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. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. 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. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. All rights reserved. Find the full text here.. 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.