Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. She has also worked at the Superior Court of San Francisco's ACCESS Center. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. ThoughtCo. I would definitely recommend Study.com to my colleagues. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. 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. Learn about the Supreme Court case, Reynolds v. Sims. v. Varsity Brands, Inc. Reynolds v. Sims (1964) Case Summary. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. All of these are characteristics of a professional legislature except meets biannually. Chief Justice Earl Warren delivered the opinion of the court. 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. During the same legislative session, lawmakers also adopted the Crawford-Webb Act, a temporary measure that provided for reapportionment in the event that the constitutional amendment was defeated by voters or struck down by the courts. [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. 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. This meant the rule could be settled by the Supreme Court with some certainty. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. The U.S. Supreme Court granted certiorari. 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. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. 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. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. The district court had not erred in its finding that neither the Crawford-Webb Act or the 67-member plan could be used as a permanent reapportionment plan, the attorneys argued. 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. The act was temporary and would only be put in place if the first plan was defeated by voters. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Legislators are elected by voters, not farms or cities or economic interests. 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. Justice John Harlan II wrote a dissenting opinion. Since population growth in the state over the next 60 years was uneven, the plaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level. Attorneys representing the voters argued that Alabama had violated a fundamental principle when it failed to reapportion its house and senate for close to 60 years. To unlock this lesson you must be a Study.com Member. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. 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. 2. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. Sims: Summary, Decision & Significance. 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. State legislatures had been reluctant to redistrict[2] because there existed general upper-class fear that if redistricting to meet population changes were carried out, voters in large, expanding or expanded urban areas would vote for confiscatory wealth redistribution[3] that would severely inhibit the power of business interests who controlled state and city governments[4] early in the century. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 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 political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to 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. Research: Josh Altic Vojsava Ramaj Create your account. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. In this case, the context was with regard to State legislatures. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. The state argued that federal courts should not interfere in state apportionment. 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. 320 lessons. 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 ones that constitutional challenges. Chappelle v. Greater Baton Rouge Airport Dist. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. 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. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. All Rights Reserved The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. Warren held that "legislators represent people, not trees or acres. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . In this case, the context was with regard to State legislatures. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. The constitution also provided for reapportionment to take place following each decennial census. 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. The U.S. Constitution undeniably protects the right to vote. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Spitzer, Elianna. The Alabama Constitution provided that there be only one state senator per county. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. All rights reserved. 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. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. There must be a causal connection between the injury and the conduct brought before the court. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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 was just one of 15 reapportionment cases the Court decided in June of 1964. Click here to contact us for media inquiries, and please donate here to support our continued expansion. 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. 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. 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. 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 history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. 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? Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. v. Abbott, Governor of Texas. 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. Its like a teacher waved a magic wand and did the work for me. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. 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? 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. 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 In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. 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. 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. 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. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. We hold that, as a basic constitutional standard, the Equal Protection Clause requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis. The case of Reynolds v. Sims arose after voters in Birmingham, Alabama, challenged the apportionment of the Alabama Legislature; the Constitution of Alabama provided for one state senator per county regardless of population differences. 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. I feel like its a lifeline. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. The decision had a major impact on state legislatures, as many states had to change their system of representation. 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. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. 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. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. The case was named for M. O. Sims, one of the voters who brought the suit, and B. 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. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. It went further to state that Legislators represent people, not trees or acres. Justice Tom C. Clark wrote a concurring opinion. 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. Reynolds v. Sims. Reynolds v. Sims (1964) Case Summary. I would definitely recommend Study.com to my colleagues. 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.

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