It went further to state that Legislators represent people, not trees or acres. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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. 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. 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. Reynolds v. Sims - Harvard University The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. 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. In order to be considered justiciable, a case must be considered to be more than just political in essence. 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. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. 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 . It is of the essence of a democratic society, Chief Justice Warren wrote. To unlock this lesson you must be a Study.com Member. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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 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. 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 district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5], Oral argument was held on November 13, 1963. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Furthermore, the existing apportionment, and also, to a lesser extent, the apportionment under the Crawford-Webb Act, presented little more than crazy quilts, completely lacking in rationality, and could be found invalid on that basis alone. Along with Baker v.Carr (1962) and Reynolds v. Sims (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. The U.S. Constitution undeniably protects the right to vote. [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. 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. Definition and Examples, Katzenbach v. Morgan: Supreme Court Case, Arguments, Impact, Browder v. Gayle: Court Case, Arguments, Impact, Obergefell v. Hodges: Supreme Court Case, Arguments, Impacts, Bolling v. Sharpe: Supreme Court Case, Arguments, Impact. 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 was just one of 15 reapportionment cases the Court decided in June of 1964. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Reynolds v. Sims. Click here to contact our editorial staff, and click here to report an error. 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. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. Even though most of that growth occurred in urban areas. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? Warren held that "legislators represent people, not trees or acres. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. Reynolds v. United States | The First Amendment Encyclopedia You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? 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. 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. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. Sims. 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. 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. As we know that federal law is superior to that of the states. 2. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. Reynolds v. Sims | Oyez - {{meta.fullTitle}} This system failed to take population size into account, leading to huge discrepancies between district . Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. No. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Its like a teacher waved a magic wand and did the work for me. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. Reynolds believed that, due to the population growth in the county where he lived and what was written in the state constitution of Alabama, there were not enough elected officials acting as representatives for the area. Reynolds v. Sims | Teaching American History Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . 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. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). 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 John Harlan II wrote a dissenting opinion. 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. All of these are characteristics of a professional legislature except meets biannually. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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. 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. Prior to the case, numerous state legislative chambers had districts containing unequal populations; for example, in the Nevada Senate, the smallest district had 568 people, while the largest had approximately 127,000 people. 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. Baker v. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al", "Reapportionment--I "One Man, One Vote" That's All She Wrote! All rights reserved. In this case, the context was with regard to State legislatures. Reynolds v. Sims (1964) - Rose Institute Reynolds v. Sims: Supreme Court Case, Arguments, Impact - ThoughtCo Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." Apply today! 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. 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. 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. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. States may have to balance representation based on population with other legislative goals like ensuring minority representation. 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 court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. 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 . Chief Justice Earl Warren delivered the 8-1 decision. v. Abbott, Governor of Texas. These individuals were voters and taxpayers from this locality. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. The Alabama Constitution provided that there be only one state senator per county. There must be a causal connection between the injury and the conduct brought before the court. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. At the end of July 1962, the district court reached a ruling. Section 1. Reynolds v. Sims (1964) Case Summary. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. 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. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. 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. are hardly of any less significance for the present and the future. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. Argued November 13, 1963. I would definitely recommend Study.com to my colleagues. Other articles where Reynolds v. Sims is discussed: Baker v. Carr: precedent, the court held in Reynolds v. Sims (1964) that both houses of bicameral legislatures had to be apportioned according to population. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. 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 He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. of Health. 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. Justice John Marshall Harlan dissented. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. Reynolds v. Sims - Case Summary and Case Brief - Legal Dictionary 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. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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. The constitution also provided for reapportionment to take place following each decennial census. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. 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. 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. 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 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. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. What was the significance of the famous case Reynolds v. Sims? copyright 2003-2023 Study.com. 23. Any one State does not have such issues. ThoughtCo. Reynolds v. Sims - Ballotpedia 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). Earl Warren | chief justice of United States | Britannica Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." After 60 years of significant population growth, some areas of the State had grown in population far more than others. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. 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. In Reynolds v. Sims, the Court was presented with two issues: The Supreme Court held that the apportionment issue concerning Alabama's legislature was justiciable. Chapter 3 Test Flashcards | Quizlet 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. 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. Among the more extreme pre-Reynolds disparities[10] claimed by Morris K. Udall: The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. As we know that federal law is superior to that of the states. It devised a reapportionment plan and passed an amendment providing for home rule to counties. 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. 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. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. The districts adhered to existing county lines. (2020, August 28). and its Licensors Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. 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. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Legislators are elected by voters, not farms or cities or economic interests." [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. A causal connection can be drawn from the injury to another source, 3. The state argued that federal courts should not interfere in state apportionment. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. In addition, the majority simply denied the argument that states were permitted to base their apportionment structures upon the Constitution itself, which requires two senators from each state despite substantially unequal populations among the states. On this Wikipedia the language links are at the top of the page across from the article title. 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. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. It also insisted that this apportionment be conducted every 10 years. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. 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. Reynolds v. Sims (1964) - U.S. Conlawpedia - GSU copyright 2003-2023 Study.com. The Fourteenth Amendment guarantees equal protection under the law. Create your account. 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.". To unlock this lesson you must be a Study.com Member. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. The second plan was called the Crawford-Webb Act. 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. 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. 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. [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. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. Reynolds v. Sims (1964) | The Rose Institute of State and Local Government [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 residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment.