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. All rights reserved. It devised a reapportionment plan and passed an amendment providing for home rule to counties. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Legislators are elected by voters, not farms or cities or economic interests. 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. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes. All Rights Reserved This meant the rule could be settled by the Supreme Court with some certainty. Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. The Court will look to see if all voting districts are fairly equal in population, and if not the Court will order that the state legislature adjust them to make them more equal. 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. Its like a teacher waved a magic wand and did the work for me. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. 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). 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. 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. In July 1962, the United States District Court for the Middle District of Alabama acknowledged the changes in Alabamas population and noted that the state legislature could legally reapportion seats based on population, as was required under Alabamas state constitution. [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. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. The rules of the House are a purely political matter, and it would be unlikely that any ruling from the Supreme Court would settle the question. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. The state argued that federal courts should not interfere in state apportionment. It should also be superior in practice as well. 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. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Before the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, as a counterbalance to towns and cities. The reason for a non-population-based Federal Senate has more to do with a compromise that allowed for the creation of a national government. Creating fair and effective representation is the main goal of legislative reapportionment and, as a result, the Equal Protection Clause guarantees the "opportunity for equal participation by all voters in the election of state legislators.". This is called the political question doctrine, and is invoked if the issue is such that a hearing by the courts will not settle the issue due to its purely political nature. Dilution of a persons vote infringes on his or her right of suffrage. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. External Relations: Moira Delaney Hannah Nelson Caroline Presnell Legislators are elected by voters, not farms or cities or economic interests. What case violated the Equal Protection Clause? 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. What is Reynolds v. 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. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas. In the landmark case of Reynolds v. Sims, which concerned representation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among the several states according to their respective numbers." 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. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). QUESTIONWhat was the significance of the famous case Reynolds v. 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. The Court then turned to the equal protection argument. The state constitution required at least . 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 . 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. These plans were to take effect in time for the 1966 elections. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by 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. 23. No. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. The district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5], Oral argument was held on November 13, 1963. Amendment. All rights reserved. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? The 1962 Alabama general election was conducted on the basis of the court-ordered plan, which was immediately appealed to the U.S. Supreme Court. However, should an issue be ruled to be justiciable, this means that one branch of the government's jurisdiction is not able to be infringed upon by other branches of government. 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. 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. It is of the essence of a democratic society, Chief Justice Warren wrote. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. Along with Baker v. Carr (1962) and Wesberry v. 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. 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. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Baker v. Carr. Oyez. In order to be considered justiciable, a case must be considered to be more than just political in essence. She also has a Bachelor's of Science in Biological Sciences from California University. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. Sounds fair, right? At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. Because this was a requirement of the Equal Protection Clause of the 14. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. 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. 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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. As a result of the decision, almost every state had to redraw its legislative districts, and power . 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." 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. 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. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." 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 most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). Reynolds was sentenced for polygamy Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. Without reapportionment, multiple districts were severely underrepresented. However, states should strive to create districts that offer representation equal to their population. 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. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. 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. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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. Create an account to start this course today. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al", "Reapportionment--I "One Man, One Vote" That's All She Wrote! 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. Sims?ANSWERA.) Research: Josh Altic Vojsava Ramaj The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. 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. 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 . The decision had a major impact on state legislatures, as many states had to change their system of representation. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Decision of One Person, One Vote Court Case, 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. California: Summary & Decision, ILTS School Counselor (235): Test Practice and Study Guide, GED Social Studies: Civics & Government, US History, Economics, Geography & World, Introduction to Human Geography: Help and Review, Foundations of Education: Certificate Program, NY Regents Exam - Global History and Geography: Help and Review, NY Regents Exam - Global History and Geography: Tutoring Solution, DSST Foundations of Education: Study Guide & Test Prep, Praxis Core Academic Skills for Educators: Reading (5713) Prep, Praxis Core Academic Skills for Educators - Writing (5723): Study Guide & Practice, What is a Magnetic Compass? Even though most of that growth occurred in urban areas. Reynolds was a resident of Jefferson County, Alabama. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. What amendment did Reynolds v Sims violate? M.O. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. Wesberry v. Sanders. Oyez. Argued November 13, 1963. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Create your account. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. 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. 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. 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. I would definitely recommend Study.com to my colleagues. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. Section 2. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. State senate districts must have roughly equal populations based on the principle of "one person, one vote". 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. She has also worked at the Superior Court of San Francisco's ACCESS Center. I feel like its a lifeline. In the case of Baker v. Carr, the court heard the argument for whether or not the Supreme Court had the right to redistrict legislative offices considering population changes in legislative districts. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. 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. 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. Sims: Summary, Decision & Significance. 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. 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. Learn about the Supreme Court case, Reynolds v. Sims. Create your account. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch copyright 2003-2023 Study.com. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them.