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. Can a state use a reapportionment plan that ignores significant shifts in population? 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. 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. 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. 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." 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. 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 Chief Justice Earl Warren delivered the 8-1 decision. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Create an account to start this course today. 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? Create an account to start this course today. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. To unlock this lesson you must be a Study.com Member. copyright 2003-2023 Study.com. Wesberry v. Sanders. Oyez. 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. A likely (not speculative) injury was suffered by an individual, 2. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Requiring states to employ honest and good faith practices when creating districts. 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 was sentenced for polygamy QUESTIONWhat was the significance of the famous case Reynolds v. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. of Health. 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 district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. 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. [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 case was decided on June 15, 1964. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. The ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. 24 chapters | It established the precedent that felons are not allowed to vote.B.) Sims, David J. Vann (of Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. Baker v. 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. 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. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 2. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. 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. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . 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. 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. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. 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. 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. (2020, August 28). Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? In dissent, Justice John Marshall Harlan II wrote that the majority had chosen to ignore the language, history, and original intent of the Equal Protection Clause, which did not extend to voting rights. Justice John Marshall Harlan dissented. It gave . Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. The Court's decision in Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. 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. Without reapportionment, multiple districts were severely underrepresented. 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. Cruzan v. Director, Missouri Dept. In 2016, the Supreme Court rejected a challenge to "one person, one vote" in Evenwel et al. Reynolds v. Sims. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. [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. I feel like its a lifeline. 1, Schuette v. Coalition to Defend Affirmative Action, Students for Fair Admissions v. President and Fellows of Harvard College, Personnel Administrator of Massachusetts v. Feeney, Mississippi University for Women v. Hogan. ThoughtCo. 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Numerous states had to change their system of representation in the state legislature. 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. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell Argued November 13, 1963. 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. 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. [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]. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. 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). [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. These three requirements are as follows: 1. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. It also insisted that this apportionment be conducted every 10 years. Sims. Chappelle v. Greater Baton Rouge Airport Dist. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. The U.S. Supreme Court affirmed the district court, holding that the, The District Court for the Middle District of Alabama found that the reapportionment plans proposed by the Alabama Legislature would not cure the. Reynolds v. Sims 1964. All rights reserved. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. It is of the essence of a democratic society, Chief Justice Warren wrote. 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. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. 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. The plaintiffs requested a declaration that "establishing the present apportionment of seats in the Alabama Legislature, were unconstitutional under the Alabama and Federal Constitutions, and an injunction against the holding of future elections for legislators until the legislature reapportioned itself in accordance with the State Constitution. Section 2. The second plan was called the Crawford-Webb Act. 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. As a result, virtually every state legislature was . 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. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. State senate districts must have roughly equal populations based on the principle of "one person, one vote". This case overturned a previous ruling or rulings, These being New Jersey, Massachusetts, New Hampshire (, Alabama Legislative Black Caucus v. Alabama, List of United States Supreme Court cases, volume 377, "The Best Supreme Court Decisions Since 1960", "Reapportionments of State Legislatures: Legal Requirement", "B. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. - Definition, Reintegrative Shaming: Definition & Theory in Criminology, Victimology: Contemporary Trends & Issues, Law Enforcement & Crime Victims: Training & Treatment, Practical Application: Measuring the Extent of Victimization, Personal Crimes: Types, Motivations & Effects, Explanations for Personal Crimes: Victim Precipitation & Situated Transactions, Impacts of Personal Crimes on Direct & Indirect Victims, Working Scholars Bringing Tuition-Free College to the Community, The plaintiff must have suffered an ''injury in fact.''. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Interns wanted: Get paid to help ensure that every voter has unbiased election information. The Alabama Constitution provided that there be only one state senator per county. The U.S. Supreme Court granted certiorari. Dilution of a persons vote infringes on his or her right of suffrage. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. There must be a causal connection between the injury and the conduct brought before the court. 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. 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. The Court then turned to the equal protection argument. Because of this principle, proper proportioning of representatives should exist in all legislative districts, to make sure that votes are about equal with the population of residents. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Reynolds was a resident of Jefferson County, Alabama. 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.
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