The Court then turned to the equal protection argument. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? Star Athletica, L.L.C. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. The constitution also provided for reapportionment to take place following each decennial census. Argued November 13, 1963. All other trademarks and copyrights are the property of their respective owners. It should also be superior in practice as well. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. 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. 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. 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). Only the Amendment process can do that. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. 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. of Health. I would definitely recommend Study.com to my colleagues. 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. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. In addition, the majority simply denied the argument that states were permitted to base their apportionment structures upon the Constitution itself, which requires two senators from each state despite substantially unequal populations among the states. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. In this case, the context was with regard to State legislatures. Amendment. ThoughtCo. Furthermore, the existing apportionment, and also, to a lesser extent, the apportionment under the Crawford-Webb Act, presented little more than crazy quilts, completely lacking in rationality, and could be found invalid on that basis alone. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. It is of the essence of a democratic society, Chief Justice Warren wrote. The decision had a major impact on state legislatures, as many states had to change their system of representation. 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. 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. It established the precedent that felons are not allowed to vote.B.) 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. Legislators are elected by voters, not farms or cities or economic interests. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. Chief Justice Earl Warren delivered the opinion of the court. Reynolds v. Sims - Harvard University There must be a causal connection between the injury and the conduct brought before the court. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14th Amendment by weighing some votes higher than another? Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. 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 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. These plans were to take effect in time for the 1966 elections. Reynolds v. Sims (1964) - U.S. Conlawpedia - GSU Reynolds was a resident of Jefferson County, Alabama. 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. After 60 years of significant population growth, some areas of the State had grown in population far more than others. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. 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. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. (2020, August 28). 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. Click here to contact our editorial staff, and click here to report an error. 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. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Reynolds v. Sims is a 1964 Supreme Court case holding that the Equal Protection Clause of the Fourteenth Amendment requires seats in a state legislature to be apportioned so that one vote equals one person residing in each state legislative district. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." External Relations: Moira Delaney Hannah Nelson Caroline Presnell Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. It called for a 106-member House and a 35-member Senate. 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 Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. Reynolds v. Sims (1964) - LII / Legal Information Institute To read more about the impact of Reynolds v. Sims click here. 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 | Oyez - {{meta.fullTitle}} The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. All rights reserved. States may have to balance representation based on population with other legislative goals like ensuring minority representation. It should also be superior in practice as well. Reynolds v. United States | The First Amendment Encyclopedia It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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. Reynolds v. Sims - Wikipedia The constitution established a state senate comprising no more than 35 members, with the actual number of senators falling between one-fourth and one-third of the number of state representatives. 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. The Fourteenth Amendment guarantees equal protection under the law. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Yes. 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. 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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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. The Alabama Constitution provided that there be only one state senator per county. 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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. and its Licensors 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. 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. 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. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Reynolds v. Sims. The 1901 Alabama Constitution provided for a house of representatives comprising no more than 105 members (with an exception provided for new counties, each of which would be entitled to at least one representative). https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. In Reynolds v. United States, 98 U.S. 145 (1879), the Supreme Court ruled unanimously that a federal law prohibiting polygamy did not violate the free exercise clause of the First Amendment. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. The case was decided on June 15, 1964. The ones that constitutional challenges. 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. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. 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. She also has a Bachelor's of Science in Biological Sciences from California University. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment.