Reynolds v. Sims is a 1964 Supreme Court case holding that the Equal Protection Clause of the Fourteenth Amendment requires seats in a state legislature to be apportioned so that one vote equals one person residing in each state legislative district. 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. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. This system failed to take population size into account, leading to huge discrepancies between district . Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. 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. 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. The U.S. Constitution undeniably protects the right to vote. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. 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. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. [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. It called for a 106-member House and a 35-member Senate. Reynolds v. Sims 1964. For instance, South Carolina had elected one state senator from each county. Sims: Summary, Decision & Significance. The District Courts remedy of temporary reapportionment was appropriate for purposes of the 1962 elections, and it allows for the reapportioned legislature a chance to find a permanent solution for Alabama. 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. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). Create your account. 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). David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. 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, English Common Law System: Definition & History, Jeremy Bentham: Biography, Theory & Ethics, Schedule of Drugs: Classification & Examples, What are Zero Tolerance Laws & Policies? It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. Sims?ANSWERA.) The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. 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. 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 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. Star Athletica, L.L.C. This system failed to take population size into account, leading to huge discrepancies between district . Reynolds v. Sims. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . The constitution also provided for reapportionment to take place following each decennial census. 320 lessons. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Reynolds v. Sims (1964) Case Summary. The Court's decision was among the first to hold that the free exercise of religion is not absolute. The second plan was called the Crawford-Webb Act. Interns wanted: Get paid to help ensure that every voter has unbiased election information. The district court drafted a temporary re-apportionment plan for the 1962 election. Section 1. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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. 24 chapters | The decision had a major impact on state legislatures, as many states had to change their system of representation. 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. As we know that federal law is superior to that of the states. 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. Only the Amendment process can do that. Voters in the states are represented by members of their state legislature. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. of Health. The state appealed the decision to the Supreme Court. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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? Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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? 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. Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. [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. 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. Spitzer, Elianna. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. 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 case of Reynolds v. Sims was initially argued November 13, 1963, but a decision on this case was not reached until June 15, 1964. 2d 506 (1964), in which the U.S. Supreme Court established the principle of one person, one vote based on the equal protection clause of the fourteenth amendment. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. Let's say your county sent five representatives to the state legislature, just like your neighboring county. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. 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. 320 lessons. "[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). Wesberry v. Sanders. Oyez. Reynolds v. Sims Significance, "legislators Represent People, Not Trees", The Census, Further Readings Appellant R. A. Reynolds Appellee M. O. Sims Appellant's Claim That representation in both houses of state legislatures must be based on population. copyright 2003-2023 Study.com. 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. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. 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. 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. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. 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. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. 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. Even though most of that growth occurred in urban areas. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). Yes. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. There must be a causal connection between the injury and the conduct brought before the court. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. Along with Baker v. Carr (1962) and Wesberry v. No. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. The act was temporary and would only be put in place if the first plan was defeated by voters. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? The Fourteenth Amendment guarantees equal protection under the law. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Legislators are elected by voters, not farms or cities or economic interests. State officials appealed, arguing that Alabamas existing and proposed reapportionment plans are constitutional and that the District Court lacked the power to reapportion the Legislature itself. It should also be superior in practice as well. 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 case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. It also insisted that this apportionment be conducted every 10 years. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. 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. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. In Reynolds v. Sims (1964), using the Supreme Court's precedent set in Baker v.Carr (1962), Warren held that representation in state legislatures must be apportioned equally on the basis of population rather than geographical areas, remarking that "legislators represent people, not acres or trees." In Miranda v. Arizona (1966)a landmark decision of the Warren court's rulings on . 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. 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. 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. Requiring states to employ honest and good faith practices when creating districts. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. M.O. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. Cruzan v. Director, Missouri Dept. 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. 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. 1, Schuette v. Coalition to Defend Affirmative Action, Students for Fair Admissions v. President and Fellows of Harvard College, Personnel Administrator of Massachusetts v. Feeney, Mississippi University for Women v. Hogan. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. 2. Before Reynolds, urban counties nationwide often had total representations similar to rural counties, and in Florida, there was a limit to three representatives even for the most populous counties. It devised a reapportionment plan and passed an amendment providing for home rule to counties. Before a person can bring a suit against their government, he or she must have standing, which requires that: Once a person has standing, then the issue must be justiciable, which means that the issue before the court is not one of a purely political nature. In the case of Baker v. Carr, the court heard the argument for whether or not the Supreme Court had the right to redistrict legislative offices considering population changes in legislative districts. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. 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. 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).
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