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. Chappelle v. Greater Baton Rouge Airport Dist. 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. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. 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. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. copyright 2003-2023 Study.com. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. The 1962 Alabama general election was conducted on the basis of the court-ordered plan, which was immediately appealed to the U.S. Supreme Court. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. She also has a Bachelor's of Science in Biological Sciences from California University. 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. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Justice Tom C. Clark wrote a concurring opinion. [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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. [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. sign . What amendment did Reynolds v Sims violate? "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Find the full text here.. There must be a causal connection between the injury and the conduct brought before the court. These plans were to take effect in time for the 1966 elections. Reynolds v. Sims 1964. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. 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. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise. There are three basic requirements for one to have legal standing in a court case when attempting to file a lawsuit, according to the laws governing the United States of America. 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. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. The Crawford-Webb Act provided 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 35-member state senate (with districts drawn to adhere to existing county lines). They were based on rational state policy that took geography into account, according to the state's attorneys. State senate districts must have roughly equal populations based on the principle of "one person, one vote". Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Chief Justice Earl Warren delivered the 8-1 decision. 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. 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. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. 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 . For the Senate, each county gets two representatives, regardless of size. This violated his equal protection rights under the 14th Amendment. 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. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. I would definitely recommend Study.com to my colleagues. Village of Arlington Heights v. Metropolitan Housing Development Corp. Regents of the University of California v. Bakke, Crawford v. Los Angeles Board of Education, Board of Education of Oklahoma City v. Dowell, Northeastern Fla. Chapter, Associated Gen. 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 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. Can a state use a reapportionment plan that ignores significant shifts in population? [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. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Even though most of that growth occurred in urban areas. The state constitution of Alabama mandated that, every ten years, populations of all the legislative districts in the state should be examined and appropriate representation, considering population, should be assigned to each of the legislative districts statewide, in accordance with the census that is taken once per decade. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. 23. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. 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. It should also be superior in practice as well. 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 was named for M. O. Sims, one of the voters who brought the suit, and B. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. 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. 2. Legislators are elected by voters, not farms or cities or economic interests. 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. 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. (2020, August 28). Amendments Equal protection clause of the U.S constitution. "[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 ones that constitutional challenges. 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 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 districts adhered to existing county lines. 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. 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. 320 lessons. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. 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. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. 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. 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. 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. 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. Spitzer, Elianna. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. 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. 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. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. However, states should strive to create districts that offer representation equal to their population. 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 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. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. 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. 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. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. 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. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. City of Cleburne v. Cleburne Living Center, Inc. Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank, Board of Trustees of the University of Alabama v. Garrett, Nevada Department of Human Resources v. Hibbs, https://en.wikipedia.org/w/index.php?title=Reynolds_v._Sims&oldid=1142377374, United States electoral redistricting case law, United States One Person, One Vote Legal Doctrine, American Civil Liberties Union litigation, United States Supreme Court cases of the Warren Court, Creative Commons Attribution-ShareAlike License 3.0, Appeal from the United States District Court for the Middle District of Alabama. Numerous states had to change their system of representation in the state legislature. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . 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. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. 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. For instance, South Carolina had elected one state senator from each county. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. A likely (not speculative) injury was suffered by an individual, 2. Legislators are elected by voters, not farms or cities or economic interests." Create an account to start this course today. 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. What case violated the Equal Protection Clause? It should also be superior in practice as well. The district courts judgement was affirmed. Its like a teacher waved a magic wand and did the work for me. [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]. 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. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. 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. 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. 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. What is Reynolds v. 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). 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. 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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. I would definitely recommend Study.com to my colleagues. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. It went further to state that Legislators represent people, not trees or acres. All rights reserved. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. This system failed to take population size into account, leading to huge discrepancies between district . 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. 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. M.O. 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 population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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. Legislative districts may deviate from strict population equality only as necessary to give representation to political subdivisions and provide for compact districts of contiguous territory. This meant the rule could be settled by the Supreme Court with some certainty. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. After 60 years of significant population growth, some areas of the State had grown in population far more than others. To unlock this lesson you must be a Study.com Member. Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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 constitution also provided for reapportionment to take place following each decennial census. 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 v. Sims: Supreme Court Case, Arguments, Impact." 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. Creating fair and effective representation is the main goal of legislative reapportionment and, as a result, the Equal Protection Clause guarantees the "opportunity for equal participation by all voters in the election of state legislators.". - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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Baker v. Carr. Oyez. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. Sims, David J. Vann (of Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. of Health. [12] He warned that: [T]he forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. The second plan was called the Crawford-Webb Act. 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. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. 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. Requiring states to employ honest and good faith practices when creating districts. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. and its Licensors On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury.