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. Dilution of a persons vote infringes on his or her right of suffrage. 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 District Court was correct to come to that holding and to reject the States proposed apportionment plans. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. These plans were to take effect in time for the 1966 elections. A causal connection can be drawn from the injury to another source, 3. 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. 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. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). 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. [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. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Amendment. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1960/6, http://www.pbs.org/wnet/supremecourt/rights/landmark_reynolds.html, http://law2.umkc.edu/faculty/projects/ftrials/conlaw/ReynoldsvSims.html, Spring 2016: Mosopefoluwa Ojo,Destiny Williams,Everette Hemphill,Trenton Jackson, [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabamas legislative apportionment was unconstitutional because it violated the 14. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. 24 chapters | The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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). 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. 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. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . QUESTIONWhat was the significance of the famous case Reynolds v. 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. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. 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. [12] He warned that: [T]he forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. 320 lessons. 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. [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]. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Legislators are elected by voters, not farms or cities or economic interests. Justice Tom C. Clark wrote a concurring opinion. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. 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: 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. All Rights Reserved Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Reynolds claimed that as his county gained in population and others around it remained stagnant, each representative to the state legislature represented more voters in Jefferson County then a neighboring county. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. Chappelle v. Greater Baton Rouge Airport Dist. 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. 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. It gave . Star Athletica, L.L.C. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. 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). Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? 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. 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? 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. Section 2. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. Click here to contact our editorial staff, and click here to report an error. Legislators are elected by voters, not farms or cities or economic interests." The state constitution required at least . 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. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. M.O. Numerous states had to change their system of representation in the state legislature. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Amendment by weighing some votes higher than another? Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings, Copyright 2023 Web Solutions LLC. 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. 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 state appealed the decision to the Supreme Court. and its Licensors Reynolds v. Sims. copyright 2003-2023 Study.com. sign . States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the 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. 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. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. This ruling was so immediately impactful to state legislatures that there was an attempt to pass a constitutional amendment to allow states to have districts of varying populations. Reynolds v. Sims is a well-known court case which made its way through district courts and ended up being heard by the United States Supreme Court. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Its like a teacher waved a magic wand and did the work for me. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. State representatives represent people, not geographic regions. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. [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. 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. of Health. 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. It went further to state that Legislators represent people, not trees or acres. 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. 24 chapters | Spitzer, Elianna. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. All of these are characteristics of a professional legislature except meets biannually. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. 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. I feel like its a lifeline. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. 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. 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. 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. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. Reynolds v. Sims 1964. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. To unlock this lesson you must be a Study.com Member. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. 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 district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. 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. Equal Protection as guaranteed by the 5th and 14th amendments require broadly that each person be treated equally in their voting power, but what equality means relies on a series of Supreme Court cases. In this case, the context was with regard to State legislatures. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a States bicameral legislature must be apportioned by population. 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. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. After 60 years of significant population growth, some areas of the State had grown in population far more than others. To read more about the impact of Reynolds v. Sims click here. "[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). Section 1. 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. I would definitely recommend Study.com to my colleagues. The Fourteenth Amendment guarantees equal protection under the law. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. 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. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). are hardly of any less significance for the present and the future. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. Reynolds v. Sims (1964) Case Summary. 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. Sims: Summary, Decision & Significance. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. [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]. 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. how to unhide caller id on infinix,