[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. Reynolds, and the citizens who banded together with him, believed that the lack of update in the apportioned representatives violated the Alabama state constitution since representatives were supposed to be updated every ten years when a census was completed. The amendment failed. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? 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. 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. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. The case was decided on June 15, 1964. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. [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. A causal connection can be drawn from the injury to another source, 3. 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 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. 100% remote. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Simply because one of Alabamas apportionment plans resembled the Federal set up of a House comprised of representatives based on population, and a Senate comprised of an equal number of representatives from each State does not mean that such a system is appropriate in a State legislature. Wesberry v. Sanders. Oyez. Before the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, as a counterbalance to towns and cities. sign . 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. What amendment did Reynolds v Sims violate? It is known as the "one person, one vote" case. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. 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. 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. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. The Alabama Constitution provided that there be only one state senator per county. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. copyright 2003-2023 Study.com. 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. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. 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. These plans were to take effect in time for the 1966 elections. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. During the same legislative session, lawmakers also adopted the Crawford-Webb Act, a temporary measure that provided for reapportionment in the event that the constitutional amendment was defeated by voters or struck down by the courts. Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances? If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. 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 was just one of 15 reapportionment cases the Court decided in June of 1964. It should also be superior in practice as well. As we know that federal law is superior to that of the states. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. 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. 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. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 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. This violated his equal protection rights under the 14th Amendment. Chief Justice Earl Warren delivered the 8-1 decision. 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. 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. Sims?ANSWERA.) Requiring states to employ honest and good faith practices when creating districts. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. 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, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Sims. Reynolds v. Sims. 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. The issues were: 1. 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. This system failed to take population size into account, leading to huge discrepancies between district . 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. Spitzer, Elianna. 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. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. Cruzan v. Director, Missouri Dept. 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. Amendment by weighing some votes higher than another? No. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. Reynolds v. Sims (1964) Case Summary. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. 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. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. All other trademarks and copyrights are the property of their respective owners. Even though most of that growth occurred in urban areas. Create your account. if(document.getElementsByClassName("reference").length==0) if(document.getElementById('Footnotes')!==null) document.getElementById('Footnotes').parentNode.style.display = 'none'; Communications: Alison Graves Carley Allensworth Abigail Campbell Sarah Groat Caitlin Vanden Boom It should also be superior in practice as well. 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. Numerous states had to change their system of representation in the state legislature. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. Sounds fair, right? Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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. Enrolling in a course lets you earn progress by passing quizzes and exams. To read more about the impact of Reynolds v. Sims click here. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. I feel like its a lifeline. This meant the rule could be settled by the Supreme Court with some certainty. 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. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. 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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. 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. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? 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. To unlock this lesson you must be a Study.com Member. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. In this case, the context was with regard to State legislatures. 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?