Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. 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. 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. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. 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 decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. In 1961, M.O. Chief Justice Earl Warren delivered the 8-1 decision. Legislators are elected by voters, not farms or cities or economic interests. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Warren held that "legislators represent people, not trees or acres. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. It should also be superior in practice as well. Can a state use a reapportionment plan that ignores significant shifts in population? sign . The Court then turned to the equal protection argument. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. If they were, the 6 million citizens of the Chicago area would hold sway in the Illinois Legislature without consideration of the problems of their 4 million fellows who are scattered in 100 other counties. What resulted from the supreme court decisions in Baker v. Carr. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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? 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. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. 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. v. Abbott, Governor of Texas. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. Once you finish this lesson, you should be able to: Once you finish this lesson, you should be able to: Give the year that Reynolds v. All rights reserved. The case was decided on June 15, 1964. [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]. [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]. Dilution of a persons vote infringes on his or her right of suffrage. 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. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. 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 decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. What case violated the Equal Protection Clause? Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 100% remote. 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. M.O. On this Wikipedia the language links are at the top of the page across from the article title. Reynolds v. Sims. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. 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. Spitzer, Elianna. 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. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. The state appealed the decision to the Supreme Court. It should also be superior in practice as well. Create an account to start this course today. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Justice Tom C. Clark wrote a concurring opinion. 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. 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. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Justice John Marshall Harlan dissented. The only vote cast not in favor of Reynolds was from Associate Justice John Marshall Harlan II, whose dissenting opinion was that the Equal Protection Clause of the 14th Amendment was not applicable when it came to voting rights. All other trademarks and copyrights are the property of their respective owners. Reynolds believed that, due to the population growth in the county where he lived and what was. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Section 1. 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. 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. To unlock this lesson you must be a Study.com Member. 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 decision had a major impact on state legislatures, as many states had to change their system of representation. 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. 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. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. 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. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Click here to contact our editorial staff, and click here to report an error. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. 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. 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. It is of the essence of a democratic society, Chief Justice Warren wrote. The second plan was called the Crawford-Webb Act. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Legislators are elected by voters, not farms or cities or economic interests. 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. 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 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. Senator Everett Dirksen of Illinois led a fight to pass a constitutional amendment allowing legislative districts based on land area, similar to the United States Senate. It also insisted that this apportionment be conducted every 10 years. Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. 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. Justice John Harlan II wrote a dissenting opinion. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. This system failed to take population size into account, leading to huge discrepancies between district . Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. 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Alabama, List of United States Supreme Court cases, volume 377, "The Best Supreme Court Decisions Since 1960", "Reapportionments of State Legislatures: Legal Requirement", "B. 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. 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. The district courts judgement was affirmed. 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. Let's say your county sent five representatives to the state legislature, just like your neighboring county. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. 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 federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Create your account. Requiring states to employ honest and good faith practices when creating districts. 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. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. 2. In this case, the context was with regard to State legislatures. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. Enrolling in a course lets you earn progress by passing quizzes and exams. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. copyright 2003-2023 Study.com. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. 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. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. 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 Create an account to start this course today. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. The plaintiffs further argued that "since population growth in the state from 1900 to 1960 had been uneven, Jefferson and other counties were now victims of serious discrimination with respect to the allocation of legislative representation" (i.e., population variations between districts created situations in which the voters of a smaller district were entitled to the same representation in the legislature as the voters of larger districts; each district). Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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. Wesberry v. Sanders. Oyez. 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What amendment did Reynolds v Sims violate? 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. The Court had already extended "one person, one vote" to all U.S. congressional districts in Wesberry v. Sanders (1964) a month before, but not to the Senate. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. 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. Sims?ANSWERA.) In this case, the context was with regard to State legislatures. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. These plans were to take effect in time for the 1966 elections. Chief Justice Earl Warren delivered the opinion of the court. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. I feel like its a lifeline. 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. It devised a reapportionment plan and passed an amendment providing for home rule to counties.
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