Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). 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. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). 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 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. The district courts judgement was affirmed. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Chappelle v. Greater Baton Rouge Airport Dist. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. Warren held that "legislators represent people, not trees or acres. Chief Justice Earl Warren delivered the 8-1 decision. External Relations: Moira Delaney Hannah Nelson Caroline Presnell This meant the rule could be settled by the Supreme Court with some certainty. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. 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. 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. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. and its Licensors The case was decided on June 15, 1964. All of these are characteristics of a professional legislature except meets biannually. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. 100% remote. Create your 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 order to be considered justiciable, a case must be considered to be more than just political in essence. In 2016, the Supreme Court rejected a challenge to "one person, one vote" in Evenwel et al. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. 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. 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. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. Argued November 13, 1963. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. The second plan was called the Crawford-Webb Act. This inherently nullifies the votes of some citizens and even weighted some more than the other since the distracting scheme did not reflect their population. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Voters in the states are represented by members of their state legislature. Requiring states to employ honest and good faith practices when creating districts. The significance of the U.S. Supreme Court decisions in Baker v. Carr and Reynolds v. Sims is that the decisions established that legislatures must be apportioned according to the one-person, one-vote standard. It went further to state that Legislators represent people, not trees or acres. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. In Reynolds v. Sims (1964), the Court ruled that the issue presented to them was justiciable, which meant that Reynolds had standing and it was an issue that was not a purely political question. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. As we know that federal law is superior to that of the states. Legislators are elected by voters, not farms or cities or economic interests. All rights reserved. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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 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). All rights reserved. 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. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. 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 Court goes beyond what this case requires by enforcing some form of one person, one vote principle. [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 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. 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. 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. All other trademarks and copyrights are the property of their respective owners. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch 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 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. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. TLDR: "That's just your opinion, man Earl." Sims and Baker v.Carr said that state governments couldn't simply iterate the form of the federal government (one chamber apportioned by population, one chamber apportioned by existing political divisions), that state legislatures and every lower level had to be one-person-one-vote-uber-alles.As Justice Frankfurter pointed out in dissent in Baker . What case violated the Equal Protection Clause? In 1961, M.O. Reynolds alleged that Jefferson County had grown considerably while other counties around it hadn't, which created an unequal apportionment since Jefferson County had the same number of representatives as the other counties. These individuals were voters and taxpayers from this locality. What resulted from the supreme court decisions in Baker v. Carr. 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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. As we know that federal law is superior to that of the states. Legislators are elected by voters, not farms or cities or economic interests." 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. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. Amendment. Reynolds believed that, due to the population growth in the county where he lived and what was. Chief Justice Earl Warren delivered the opinion of the court. 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. Section 1. [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabamas legislative apportionment was unconstitutional because it violated the 14th Amendments Equal protection clause of the U.S constitution. 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. 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. 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. Reynolds v. Sims. The case was named for M. O. Sims, one of the voters who brought the suit, and B. 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. I feel like its a lifeline. 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. 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. It established the precedent that felons are not allowed to vote.B.) Reynolds v. Sims. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. 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. 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. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. v. Abbott, Governor of Texas. 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. Yes. 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. She has also worked at the Superior Court of San Francisco's ACCESS Center. Spitzer, Elianna. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. Numerous states had to change their system of representation in the state legislature. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Terms of Use, Reynolds v. Sims - "legislators Represent People, Not Trees", Law Library - American Law and Legal Information, Notable Trials and Court Cases - 1963 to 1972, Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings. 2. 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. copyright 2003-2023 Study.com. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. are hardly of any less significance for the present and the future. 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In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. 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. 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. Along with Baker v. Carr (1962) and Wesberry v. [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. 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 question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . 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. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, 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. Cruzan v. Director, Missouri Dept. 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. Reynolds v. Sims (1964) Case Summary. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Wesberry v. Sanders. Oyez. 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 should also be superior in practice as well. As a result, virtually every state legislature was . U.S. Supreme Court Cases: Study Guide & Review, Malloy v. 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