It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 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. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. 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. It went further to state that Legislators represent people, not trees or acres. 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 United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. 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. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. [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. What is Reynolds v. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Justice Tom C. Clark wrote a concurring opinion. 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. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell In 1961, M.O. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. Star Athletica, L.L.C. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. 320 lessons. v. Abbott, Governor of Texas. 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. Enrolling in a course lets you earn progress by passing quizzes and exams. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Justice John Marshall Harlan dissented. 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 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. Learn about the Supreme Court case, Reynolds v. Sims. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. This system failed to take population size into account, leading to huge discrepancies between district . What amendment did Reynolds v Sims violate? Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. The case of Reynolds v. Sims arose after voters in Birmingham, Alabama, challenged the apportionment of the Alabama Legislature; the Constitution of Alabama provided for one state senator per county regardless of population differences. 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. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). [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. [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. It went further to state that Legislators represent people, not trees or acres. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? No. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. 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. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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? Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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. 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 federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. 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. Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. Create an account to start this course today. 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. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. 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. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. Sanders, Reynolds v. Sims has served as a significant precedent for a broad reading of the equal protection clause to include political rights like voting, and it has been a foundation for the involvement of federal courts in the close scrutiny, supervision, and even creation of congressional and state legislative districts in many states. 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. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Enrolling in a course lets you earn progress by passing quizzes and exams. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." O'Gorman & Young, Inc. v. Hartford Fire Insurance Co. Dobbs v. Jackson Women's Health Organization, Planned Parenthood of Central Missouri v. Danforth, City of Akron v. Akron Center for Reproductive Health, Thornburgh v. American College of Obstetricians & Gynecologists, Ohio v. Akron Center for Reproductive Health, Ayotte v. Planned Parenthood of Northern New England. 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 a case decided by the Supreme Court of the United States in 1964. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. 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. It should also be superior in practice as well. It also insisted that this apportionment be conducted every 10 years. 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. All rights reserved. The ones that constitutional challenges. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. copyright 2003-2023 Study.com. 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. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. All other trademarks and copyrights are the property of their respective owners. To unlock this lesson you must be a Study.com Member. Within two years, the boundaries of legislative districts had been redrawn all across the nation. 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. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. The state appealed the decision to the Supreme Court. Because this was a requirement of the Equal Protection Clause of the 14. 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 second plan was called the Crawford-Webb Act. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. Reynolds claimed that as his county gained in population and others around it remained stagnant, each representative to the state legislature represented more voters in Jefferson County then a neighboring county. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. All other trademarks and copyrights are the property of their respective owners. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. The Alabama Constitution provided that there be only one state senator per county. The Fourteenth Amendment guarantees equal protection under the law. 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. Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Chief Justice Earl Warren delivered the opinion of the court. On this Wikipedia the language links are at the top of the page across from the article title. 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. For instance, South Carolina had elected one state senator from each county. 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. [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 Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. Reynolds v. Sims (1964) Case Summary. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. 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. What case violated the Equal Protection Clause? Within two years, the boundaries of legislative districts had been redrawn all across the nation. To determine if an issue is justiciable, the Court will look at the nature of the issue, and if it is one dealing with the political power of either the executive or legislative branches, and if it is unlikely that a ruling by the courts will settle the issue, then is it a political question and is non-justiciable. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. In this case, the context was with regard to State legislatures. 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. Its like a teacher waved a magic wand and did the work for me. Without reapportionment, multiple districts were severely underrepresented. 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. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. She also has a Bachelor's of Science in Biological Sciences from California University. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, League of United Latin American Citizens v. Perry, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. if(document.getElementsByClassName("reference").length==0) if(document.getElementById('Footnotes')!==null) document.getElementById('Footnotes').parentNode.style.display = 'none'; Communications: Alison Graves Carley Allensworth Abigail Campbell Sarah Groat Caitlin Vanden Boom After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. He also alleged that by not doing so, the state was denying the voters and residents of his country their full representation under Alabama law, which violated their equal protection rights found in the 14th Amendment. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. 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). 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. 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. 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. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. 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. In Reynolds v. Sims, the Court was presented with two issues: The Supreme Court held that the apportionment issue concerning Alabama's legislature was justiciable. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. 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. 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. They were based on rational state policy that took geography into account, according to the state's attorneys. The constitution also provided for reapportionment to take place following each decennial census. 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. As we know that federal law is superior to that of the states. These three requirements are as follows: 1. 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. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. 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. v. Abbott, Governor of Texas. 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. 100% remote. 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. 24 chapters | Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. The U.S. Supreme Court granted certiorari. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. A likely (not speculative) injury was suffered by an individual, 2. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Reynolds, and the citizens who banded together with him, believed that the lack of update in the apportioned representatives violated the Alabama state constitution since representatives were supposed to be updated every ten years when a census was completed. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. These plans were to take effect in time for the 1966 elections. However, should an issue be ruled to be justiciable, this means that one branch of the government's jurisdiction is not able to be infringed upon by other branches of government. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. 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. Justices for the Court: Hugo L. Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Chief Justice Earl Warren, Byron R. White. This is called the political question doctrine, and is invoked if the issue is such that a hearing by the courts will not settle the issue due to its purely political nature. 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 case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Spitzer, Elianna. 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. Only the Amendment process can do that. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. I would definitely recommend Study.com to my colleagues. are hardly of any less significance for the present and the future. 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. There must be a causal connection between the injury and the conduct brought before the court. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. I feel like its a lifeline. 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. 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. In order to be considered justiciable, a case must be considered to be more than just political in essence. Spitzer, Elianna. Legislators are elected by voters, not farms or cities or economic interests. Justice John Harlan II wrote a dissenting opinion. 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.

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