In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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. Whatever may be thought of this holding as a piece of political ideology -- and even on that score, the political history and practices of this country from its earliest beginnings leave wide room for debate -- I think it demonstrable that the Fourteenth Amendment does not impose this political tenet on the States or authorize this Court to do so. 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. 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. 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. The reaction to the decision was so strong that a United States senator tried to pass a constitutional amendment that would allow states to draw districts based on geography rather than population. The case was decided on June 15, 1964. At the end of July 1962, the district court reached a ruling. [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. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Create an account to start this course today. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. All of these are characteristics of a professional legislature except meets biannually. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. It also insisted that this apportionment be conducted every 10 years. 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. This meant the rule could be settled by the Supreme Court with some certainty. 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. It went further to state that Legislators represent people, not trees or acres. To determine if an issue is justiciable, the Court will look at the nature of the issue, and if it is one dealing with the political power of either the executive or legislative branches, and if it is unlikely that a ruling by the courts will settle the issue, then is it a political question and is non-justiciable. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Enrolling in a course lets you earn progress by passing quizzes and exams. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. Along with Baker v. Carr (1962) and Wesberry v. Sanders (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. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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. The state argued that federal courts should not interfere in state apportionment. 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 order to be considered justiciable, a case must be considered to be more than just political in essence. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. It should also be superior in practice as well. State representatives represent people, not geographic regions. Definition and Examples, Katzenbach v. Morgan: Supreme Court Case, Arguments, Impact, Browder v. Gayle: Court Case, Arguments, Impact, Obergefell v. Hodges: Supreme Court Case, Arguments, Impacts, Bolling v. Sharpe: Supreme Court Case, Arguments, Impact. 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. 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. It was argued that it was unnecessary for the Supreme Court to interfere with how states apportioned their legislative districts, and that the 14th Amendment rights of Alabama voters were not being violated. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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. 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. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Supreme Court Overturning Reynolds v. Sims: Chances - reddit The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. [5] In New Hampshire the state constitutions, since January 1776, had always called for the state senate to be apportioned based on taxes paid, rather than on population. 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. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. 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. Create an account to start this course today. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? This system failed to take population size into account, leading to huge discrepancies between district . 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. The districts adhered to existing county lines. 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. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. Reynolds v. Sims (1964) Summary [Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabama's legislative apportionment was unconstitutional because it violated the 14th Amendment's Equal protection clause of the U.S constitution. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. 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. When the Court applied this rule to Alabama's then-current apportionment, it ruled that their unequal apportionment violated the voters' equal protection rights protection under the 14th Amendment. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Justice John Harlan II wrote a dissenting opinion. 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. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Sims?ANSWERA.) http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. Spitzer, Elianna. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. Reynolds v. Sims legal definition of Reynolds v. Sims 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. Justices for the Court: Hugo L. Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Chief Justice Earl Warren, Byron R. White. 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. 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. Chapter 3 Test Flashcards | Quizlet 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. 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. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). 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. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? 320 lessons. Learn about the Supreme Court case, Reynolds v. Sims. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. State senate districts must have roughly equal populations based on the principle of "one person, one vote". I would definitely recommend Study.com to my colleagues.