Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. of Health. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Create your account. 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. Its like a teacher waved a magic wand and did the work for me. It devised a reapportionment plan and passed an amendment providing for home rule to counties. QUESTIONWhat was the significance of the famous case Reynolds v. She also has a Bachelor's of Science in Biological Sciences from California University. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. 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. The act was temporary and would only be put in place if the first plan was defeated by voters. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. 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). Justice Tom Clark wrote a concurring opinion which was joined by no other justice. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. 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. 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. Sounds fair, right? Baker v. Carr: Supreme Court Case, Arguments, Impact, The Civil Rights Act of 1866: History and Impact, Shaw v. Reno: Supreme Court Case, Arguments, Impact, What Is A Poll Tax? Justice John Marshall Harlan dissented. Research: Josh Altic Vojsava Ramaj The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. The second plan was called the Crawford-Webb Act. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Spitzer, Elianna. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). Dilution of a persons vote infringes on his or her right of suffrage. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 320 lessons. State senate districts must have roughly equal populations based on the principle of "one person, one vote". 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. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? These individuals were voters and taxpayers from this locality. 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. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. v. Varsity Brands, Inc. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. All Rights Reserved 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. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. 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. 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 (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. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? TLDR: "That's just your opinion, man Earl." Sims and Baker v.Carr said that state governments couldn't simply iterate the form of the federal government (one chamber apportioned by population, one chamber apportioned by existing political divisions), that state legislatures and every lower level had to be one-person-one-vote-uber-alles.As Justice Frankfurter pointed out in dissent in Baker . 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. 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. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." [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 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. These plans were to take effect in time for the 1966 elections. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. In the landmark case of Reynolds v. Sims, which concerned representation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among the several states according to their respective numbers." Chief Justice Earl Warren delivered the 8-1 decision. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. Its like a teacher waved a magic wand and did the work for me. 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. 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. 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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. [13], In a 2015 Time Magazine survey of over 50 law professors, both Erwin Chemerinsky (Dean, UC Berkeley School of Law) and Richard Pildes (NYU School of Law) named Reynolds v. Sims the "best Supreme Court decision since 1960", with Chemerinsky noting that in his opinion, the decision made American government "far more democratic and representative."[1]. For instance, South Carolina had elected one state senator from each county. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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. State officials appealed, arguing that the existing and proposed reapportionment plans are constitutional, and that the district court lacked the power to order temporary reapportionment. All rights reserved. Yes. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. 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. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. Only the Amendment process can do that. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. 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. v. Abbott, Governor of Texas. It should also be superior in practice as well. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 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. 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. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. It established the precedent that felons are not allowed to vote.B.) It is of the essence of a democratic society, Chief Justice Warren wrote. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. [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 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. Enrolling in a course lets you earn progress by passing quizzes and exams. Let's say your county sent five representatives to the state legislature, just like your neighboring county. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. 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? Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. The constitution also provided for reapportionment to take place following each decennial census. v. Abbott, Governor of Texas. We are advised that States can rationally consider . Section 2. Enrolling in a course lets you earn progress by passing quizzes and exams. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. copyright 2003-2023 Study.com. 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 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. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. 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. 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. State representatives represent people, not geographic regions. 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. 2. 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. It was argued that it was unnecessary for the Supreme Court to interfere with how states apportioned their legislative districts, and that the 14th Amendment rights of Alabama voters were not being violated. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . 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. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. External Relations: Moira Delaney Hannah Nelson Caroline Presnell 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. [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]. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. 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. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. 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. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. In a majority opinion joined by five other justices, Chief Justice Earl Warren ruled that the Fourteenth Amendment's Equal Protection Clause requires states to establish state legislative electoral districts roughly equal in population. What case violated the Equal Protection Clause? Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Interns wanted: Get paid to help ensure that every voter has unbiased election information. The Fourteenth Amendment guarantees equal protection under the law. 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. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. 320 lessons. As we know that federal law is superior to that of the states. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. Wesberry v. Sanders. Oyez. 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. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. The state argued that federal courts should not interfere in state apportionment. The district courts judgement was affirmed. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. 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. Reynolds v. Sims. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. The U.S. Constitution undeniably protects the right to vote. Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. 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). Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. Argued November 13, 1963. Cruzan v. Director, Missouri Dept. 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. Create your account. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Amendment. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. She has also worked at the Superior Court of San Francisco's ACCESS Center. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. 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. All other trademarks and copyrights are the property of their respective owners. Justice Tom C. Clark wrote a concurring opinion. 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 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). 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. 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. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. 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. "[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). Learn about the Supreme Court case, Reynolds v. Sims. 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. 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. The decision of this case led to the adoption of the one person, one vote principle, which is a rule that is applied to make sure that legislative districts are zoned so that they are closer to equal in population, in accordance with when the census is taken every ten years. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. A causal connection can be drawn from the injury to another source, 3. Numerous states had to change their system of representation in the state legislature. Along with Baker v. Carr (1962) and Wesberry v. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. 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. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. 24 chapters | The district court drafted a temporary re-apportionment plan for the 1962 election. The districts adhered to existing county lines. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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. Reynolds v. Sims (1964) Case Summary. The case was decided on June 15, 1964. [4][5], On August 26, 1961, the plaintiffs in the suit, a group of voters residing in Jefferson County, Alabama, filed suit in the United States District Court for the Middle District of Alabama. The Court's decision in Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. 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. 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.