The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. In Reynolds v. United States, 98 U.S. 145 (1879), the Supreme Court ruled unanimously that a federal law prohibiting polygamy did not violate the free exercise clause of the First Amendment. 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. 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. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional.The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. What resulted from the supreme court decisions in Baker v. Carr. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. The significance of the U.S. Supreme Court decisions in Baker v. Carr and Reynolds v. Sims is that the decisions established that legislatures must be apportioned according to the one-person, one-vote standard. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. Justice Potter Stewart also issued a concurring opinion, in which he argued that while many of the schemes of representation before the court in the case were egregiously undemocratic and clearly violative of equal protection, it was not for the Court to provide any guideline beyond general reasonableness for apportionment of districts. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. She has also worked at the Superior Court of San Francisco's ACCESS Center. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. 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. What amendment did Reynolds v Sims violate? 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? 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. 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. 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.". Reynolds alleged that Jefferson County had grown considerably while other counties around it hadn't, which created an unequal apportionment since Jefferson County had the same number of representatives as the other counties. 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. 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. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. Some states refused to engage in regular redistricting, while others enshrined county by county representation (Like the federal government does with state by state representation) in their constitutions. It established the precedent that felons are not allowed to vote.B.) The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. This system failed to take population size into account, leading to huge discrepancies between district . 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. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. 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. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. 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). 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. Click here to contact us for media inquiries, and please donate here to support our continued expansion. All rights reserved. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Justice Tom C. Clark wrote a concurring opinion. Reynolds v. Sims (1964) Summary [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabama's legislative apportionment was unconstitutional because it violated the 14th Amendment's Equal protection clause of the U.S constitution. 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. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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. Create your account. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. 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 U.S. Supreme Court granted certiorari. Legislators are elected by voters, not farms or cities or economic interests." Cruzan v. Director, Missouri Dept. The second plan was called the Crawford-Webb Act. 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. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . Because this was a requirement of the Equal Protection Clause of the 14th Amendment. 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. 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. We are advised that States can rationally consider . The constitution also provided for reapportionment to take place following each decennial census. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. As a result, virtually every state legislature was . Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. 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. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. In Reynolds v. Sims (1964), the Court ruled that the issue presented to them was justiciable, which meant that Reynolds had standing and it was an issue that was not a purely political question. 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. 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. 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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. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. On this Wikipedia the language links are at the top of the page across from the article title. 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. M.O. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 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. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. 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. Amendments Equal protection clause of the U.S constitution. 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. 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. Numerous states had to change their system of representation in the state legislature. (2020, August 28). A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. Reynolds v. Sims (1964) Case Summary. Baker v. Carr. Oyez. 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. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. 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. v. Varsity Brands, Inc. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 24 chapters | To unlock this lesson you must be a Study.com Member. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Without reapportionment, multiple districts were severely underrepresented. The state appealed the decision to the Supreme Court. v. Abbott, Governor of Texas. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. 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. 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. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. Voters from Jefferson County, Alabama challenged the apportionment structure of their State House and Senate, which required each county to have at least one representative, regardless of size. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. To unlock this lesson you must be a Study.com Member. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. 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. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. They were based on rational state policy that took geography into account, according to the state's attorneys. 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. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. It should also be superior in practice as well. [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]. Requiring states to employ honest and good faith practices when creating districts. This system failed to take population size into account, leading to huge discrepancies between district . Instead, the issues were being left open due to the Court's reluctance to avoid the problem. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. The amendment failed. Within two years, the boundaries of legislative districts had been redrawn all across the nation. I feel like its a lifeline. Spitzer, Elianna. Within two years, the boundaries of legislative districts had been redrawn all across the nation. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. 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." After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. These plans were to take effect in time for the 1966 elections. However, two years before the Reynolds case, in Baker v. Carr (1962), the Supreme Court ruled that a redistricting attempt by the Tennessee legislature was a justiciable issue because the issue dealt with the interpretation of a state law and not their political process. 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. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. Ratio variances as great as 41 to 1 from one senatorial district to another existed in the Alabama Senate (i.e., the number of eligible voters voting for one senator was in one case 41 times the number of voters in another). Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. Thus his vote was diluted in value because the group of representatives from his state had no more influence than a county with half the population. The district court drafted a temporary re-apportionment plan for the 1962 election. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Section 2. 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. 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). Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Decision of One Person, One Vote Court Case, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. California: Summary & Decision, ILTS School Counselor (235): Test Practice and Study Guide, GED Social Studies: Civics & Government, US History, Economics, Geography & World, Introduction to Human Geography: Help and Review, Foundations of Education: Certificate Program, NY Regents Exam - Global History and Geography: Help and Review, NY Regents Exam - Global History and Geography: Tutoring Solution, DSST Foundations of Education: Study Guide & Test Prep, Praxis Core Academic Skills for Educators: Reading (5713) Prep, Praxis Core Academic Skills for Educators - Writing (5723): Study Guide & Practice, What is a Magnetic Compass?
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