Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. The case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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. are hardly of any less significance for the present and the future. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. [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. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. It is of the essence of a democratic society, Chief Justice Warren wrote. The Fourteenth Amendment guarantees equal protection under the law. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Once you finish this lesson, you should be able to: Once you finish this lesson, you should be able to: Give the year that Reynolds v. All rights reserved. Reynolds was a resident of Jefferson County, Alabama. 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. Chief Justice Earl Warren delivered the opinion of the court. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Within two years, the boundaries of legislative districts had been redrawn all across the nation. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. Research: Josh Altic Vojsava Ramaj Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. 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 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. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. 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. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. It devised a reapportionment plan and passed an amendment providing for home rule to counties. Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. The Court then turned to the equal protection argument. 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. Today's holding is that the Equal Protection Clause of the Fourteenth Amendment requires every State to structure its legislature so that all the members of each house represent substantially the same number of people; other factors may be given play only to the extent that they do not significantly encroach on this basic 'population' principle. 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." The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. The act was temporary and would only be put in place if the first plan was defeated by voters. Reynolds v. Sims: Summary, Decision & Significance Instructor: Kenneth Poortvliet Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time. Spitzer, Elianna. Create an account to start this course today. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. It is known as the "one person, one vote" case. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. Argued November 13, 1963. I would definitely recommend Study.com to my colleagues. As we know that federal law is superior to that of the states. This meant the rule could be settled by the Supreme Court with some certainty. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. 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. 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. Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. For instance, South Carolina had elected one state senator from each county. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. v. Abbott, Governor of Texas. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. [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]. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. Legislators are elected by voters, not farms or cities or economic interests. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. 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 . 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. 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. 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. Chappelle v. Greater Baton Rouge Airport Dist. (2020, August 28). Section 2. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. All other trademarks and copyrights are the property of their respective owners. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Legislators are elected by voters, not farms or cities or economic interests." ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. [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. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Chief Justice Earl Warren delivered the 8-1 decision. 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. The U.S. Constitution undeniably protects the right to vote. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . 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. As a result, virtually every state legislature was . Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . 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. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. 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. 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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. 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. 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. [4][5], On July 21, 1962, the district court found that Alabama's existing apportionment system violated the Equal Protection Clause of the Amendment XIV, United States Constitution. However, allegations of State Senates being redundant arose, as all states affected retained their state senates, with state senators being elected from single-member districts, rather than abolishing the upper houses, as had been done in 1936 in Nebraska[b] (and in the provinces of Canada), or switching to electing state senators by proportional representation from several large multi-member districts or from one statewide at-large district, as was done in Australia. 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 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). Reynolds v. Sims (1964) Case Summary. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. In 1961, M.O. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. It gave . It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. The decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment.
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