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We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 24 chapters | 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. For instance, South Carolina had elected one state senator from each county. 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. Shortly after the Supreme Court handed down its decision in Baker v. Carr in March of 1962, under pressure from the federal district court that was still considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. 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. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. 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. Village of Arlington Heights v. Metropolitan Housing Development Corp. Regents of the University of California v. Bakke, Crawford v. Los Angeles Board of Education, Board of Education of Oklahoma City v. Dowell, Northeastern Fla. Chapter, Associated Gen. Perhaps most importantly, this case provided the important precedent that courts could intervene in the district schemes of a state if the legislatures reapportionment was not in line with the Equal Protection clause of the Fourteenth Amendment. 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. In order to be considered justiciable, a case must be considered to be more than just political in essence. 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. M.O. This meant the rule could be settled by the Supreme Court with some certainty. There are three basic requirements for one to have legal standing in a court case when attempting to file a lawsuit, according to the laws governing the United States of America. We are advised that States can rationally consider . Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. A causal connection can be drawn from the injury to another source, 3. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. In 2016, the Supreme Court rejected a challenge to "one person, one vote" in Evenwel et al. Amendments Equal protection clause of the U.S constitution. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 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. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Its like a teacher waved a magic wand and did the work for me. 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. Simply stated, an individual's right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State. 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. Create your account. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. Since under neither the existing apportionment provisions nor either of the proposed plans was either of the houses of the Alabama Legislature apportioned on a population basis, the District Court correctly held that all three of these schemes were constitutionally invalid. Spitzer, Elianna. 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. of Health. Reynolds was a resident of Jefferson County, Alabama. 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. [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 next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. 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. Reynolds v. Sims (1964) Case Summary. 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. This violated his equal protection rights under the 14th 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. In this case, the context was with regard to State legislatures. Section 1. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. This system failed to take population size into account, leading to huge discrepancies between district . It also insisted that this apportionment be conducted every 10 years. 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. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. 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. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. "[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). Justice John Marshall Harlan dissented. 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 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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. Warren held that "legislators represent people, not trees or acres. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Click here to contact our editorial staff, and click here to report an error. Amendment. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Acknowledging the Court's long standing desire to stay away from the political power struggles within the state governments, the Court noted that since its decision in Baker v. Carr, there have been several cases filed across the country regarding the dilution of voters' rights due to inequitable apportionment. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). 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. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Post-Reynolds, a number of states had to change their apportionment plans to take population into 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. 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 district court drafted a temporary re-apportionment plan for the 1962 election. 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. 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." 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. 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. Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Sims: Summary, Decision & Significance. Interns wanted: Get paid to help ensure that every voter has unbiased election information. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." 24 chapters | Justice Tom Clark wrote a concurring opinion which was joined by no other justice. 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. Since population growth in the state over the next 60 years was uneven, the plaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level. 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 . 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. The Court then turned to the equal protection argument. Can a state use a reapportionment plan that ignores significant shifts in population? External Relations: Moira Delaney Hannah Nelson Caroline Presnell Justice Tom C. Clark wrote a concurring opinion. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. 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. 2. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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). Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. On this Wikipedia the language links are at the top of the page across from the article title. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. The state argued that federal courts should not interfere in state apportionment. Justice Potter Stewart also issued a concurring opinion, in which he argued that while many of the schemes of representation before the court in the case were egregiously undemocratic and clearly violative of equal protection, it was not for the Court to provide any guideline beyond general reasonableness for apportionment of districts. 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. 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. 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. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. What is Reynolds v. 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. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. 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. 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. It devised a reapportionment plan and passed an amendment providing for home rule to counties. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. 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. 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. Within two years, the boundaries of legislative districts had been redrawn all across the nation. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. 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. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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. Amendment by weighing some votes higher than another? After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. I would definitely recommend Study.com to my colleagues. 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 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. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. The constitution also provided for reapportionment to take place following each decennial census. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. Argued November 13, 1963. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Sounds fair, right? 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. And in deciding the dispute, the Court applied the one-person one-vote rule, therefore holding that the districts were not equal in population size and should be reapportioned to ensure equal representation. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Sims?ANSWERA.) Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. 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. These individuals were voters and taxpayers from this locality. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell 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. It went further to state that Legislators represent people, not trees or acres. What amendment did Reynolds v Sims violate? - Definition, Reintegrative Shaming: Definition & Theory in Criminology, Victimology: Contemporary Trends & Issues, Law Enforcement & Crime Victims: Training & Treatment, Practical Application: Measuring the Extent of Victimization, Personal Crimes: Types, Motivations & Effects, Explanations for Personal Crimes: Victim Precipitation & Situated Transactions, Impacts of Personal Crimes on Direct & Indirect Victims, Working Scholars Bringing Tuition-Free College to the Community, The plaintiff must have suffered an ''injury in fact.''.