These individuals were voters and taxpayers from this locality. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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. 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. Because this was a requirement of the Equal Protection Clause of the 14th 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]. States may have to balance representation based on population with other legislative goals like ensuring minority representation. 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. Yes. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. 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. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. 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. It went further to state that Legislators represent people, not trees or acres. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Because this was a requirement of the Equal Protection Clause of the 14. Legislators are elected by voters, not farms or cities or economic interests. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. 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. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. In Reynolds v. Sims (1964) the U.S. Supreme Court ruled that states must create legislative districts that each have a substantially equal number of voters to comply with the Equal Protection Clause of the Fourteenth Amendment. 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. It also insisted that this apportionment be conducted every 10 years. 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. The act was temporary and would only be put in place if the first plan was defeated by voters. 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 M.O. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). Research: Josh Altic Vojsava Ramaj Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. Voters in the states are represented by members of their state legislature. 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. v. Varsity Brands, Inc. 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. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. The case was decided on June 15, 1964. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." Justice John Marshall Harlan dissented. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. What resulted from the supreme court decisions in Baker v. Carr. 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. It called for a 106-member House and a 35-member Senate. 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. Click here to contact us for media inquiries, and please donate here to support our continued expansion. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. 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. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, 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. These three requirements are as follows: 1. 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. Its like a teacher waved a magic wand and did the work for me. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. All other trademarks and copyrights are the property of their respective owners. The issues were: 1. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional.The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. Without reapportionment, multiple districts were severely underrepresented. Reynolds v. Sims. 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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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. 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. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. 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. Section 2. 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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Click here to contact our editorial staff, and click here to report an error. 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. It gave . Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. The state argued that federal courts should not interfere in state apportionment. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. It devised a reapportionment plan and passed an amendment providing for home rule to counties. 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. 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. The Court's decision was among the first to hold that the free exercise of religion is not absolute. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. State senate districts must have roughly equal populations based on the principle of "one person, one vote". Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances? Create your account. Amendment. 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. However, states should strive to create districts that offer representation equal to their population. 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. As a result of the decision, almost every state had to redraw its legislative districts, and power . All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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. 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. 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. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion.