The Court's decision was among the first to hold that the free exercise of religion is not absolute. 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. Legislators are elected by voters, not farms or cities or economic interests." In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. 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. 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. To read more about the impact of Reynolds v. Sims click here. Its like a teacher waved a magic wand and did the work for me. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. No. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Before Reynolds, urban counties nationwide often had total representations similar to rural counties, and in Florida, there was a limit to three representatives even for the most populous counties. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. copyright 2003-2023 Study.com. I would definitely recommend Study.com to my colleagues. 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. 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. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. [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. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. QUESTIONWhat was the significance of the famous case Reynolds v. 1, Schuette v. Coalition to Defend Affirmative Action, Students for Fair Admissions v. President and Fellows of Harvard College, Personnel Administrator of Massachusetts v. Feeney, Mississippi University for Women v. Hogan. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. The districts adhered to existing county lines. The second plan was called the Crawford-Webb Act. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. 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. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). All Rights Reserved Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. Reynolds v. Sims. I feel like its a lifeline. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. A likely (not speculative) injury was suffered by an individual, 2. To unlock this lesson you must be a Study.com Member. 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. The constitution also provided for reapportionment to take place following each decennial census. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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 1961, M.O. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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 United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. 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. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. They were based on rational state policy that took geography into account, according to the state's attorneys. The state appealed the decision to the Supreme Court. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. The act was temporary and would only be put in place if the first plan was defeated by voters. 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. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. 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. 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. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. 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. It should also be superior in practice as well. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. The case of Reynolds v. Sims was ruled to be justiciable, which means that the legislative portion of the United States government had already voted on the issue regarding a similar which case, which renders the actual case to be moot, or not matter. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Reynolds believed that, due to the population growth in the county where he lived and what was. These individuals were voters and taxpayers from this locality. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. The issues were: 1. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. 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. 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. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. 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 amendment failed. 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. 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. 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. 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. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. 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. 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. 320 lessons. [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. [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: Supreme Court Case, Arguments, Impact." 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. 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 . 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). The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. 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. 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. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. This meant the rule could be settled by the Supreme Court with some certainty. [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]. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. Justice Tom C. Clark wrote a concurring opinion. Reynolds was a resident of Jefferson County, Alabama. She also has a Bachelor's of Science in Biological Sciences from California University. 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. (2020, August 28). 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. 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. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. 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. 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 rendered at least one house of most legislatures unconstitutional. 2. 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." Sims?ANSWERA.) A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. I would definitely recommend Study.com to my colleagues. 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 decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. 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. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. 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. The U.S. Supreme Court granted certiorari. 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. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. v. Abbott, Governor of Texas. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. 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. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. Legislators are elected by voters, not farms or cities or economic interests. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. 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. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. This violated his equal protection rights under the 14th Amendment. 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 The ones that constitutional challenges. 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. 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. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. 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 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. Section 2. The state constitution required at least . A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. This system failed to take population size into account, leading to huge discrepancies between district . Cruzan v. Director, Missouri Dept. Amendment by weighing some votes higher than another? 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. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . 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. 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. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. [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. 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. Legislators are elected by voters, not farms or cities or economic interests. 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. Amendment. All of these are characteristics of a professional legislature except meets biannually. We are advised that States can rationally consider . Sims, David J. Vann (of Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. Chief Justice Earl Warren delivered the opinion of the court. 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.