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. 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. Because this was a requirement of the Equal Protection Clause of the 14. The political question doctrine states that, when it is invoked, that a case is unable to be settled in the court of law if the issue it addresses stems from an essence that is merely political in its nature. What case violated the Equal Protection Clause? Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. I would definitely recommend Study.com to my colleagues. v. Abbott, Governor of Texas. Numerous states had to change their system of representation in the state legislature. A likely (not speculative) injury was suffered by an individual, 2. Sounds fair, right? Interns wanted: Get paid to help ensure that every voter has unbiased election information. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. 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. It should also be superior in practice as well. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Reynolds claimed that as his county gained in population and others around it remained stagnant, each representative to the state legislature represented more voters in Jefferson County then a neighboring county. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. Terms of Use, Reynolds v. Sims - "legislators Represent People, Not Trees", Law Library - American Law and Legal Information, Notable Trials and Court Cases - 1963 to 1972, Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings. Along with Baker v. Carr (1962) and Wesberry v. The U.S. Constitution undeniably protects the right to vote. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. 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. 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. The Court's decision was among the first to hold that the free exercise of religion is not absolute. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. ThoughtCo. 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. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). Sims?ANSWERA.) It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 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. 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. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. 320 lessons. Legislators are elected by voters, not farms or cities or economic interests." 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." The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. copyright 2003-2023 Study.com. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. It also insisted that this apportionment be conducted every 10 years. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. The Fourteenth Amendment guarantees equal protection under the law. 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. 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. 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 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. In the case of Baker v. Carr, the court heard the argument for whether or not the Supreme Court had the right to redistrict legislative offices considering population changes in legislative districts. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. 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. In Reynolds v. Sims (1964), using the Supreme Court's precedent set in Baker v.Carr (1962), Warren held that representation in state legislatures must be apportioned equally on the basis of population rather than geographical areas, remarking that "legislators represent people, not acres or trees." In Miranda v. Arizona (1966)a landmark decision of the Warren court's rulings on . Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. 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. 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. [5][6] Illinois did not redistrict between 1910 and 1955,[7] while Alabama and Tennessee had at the time of Reynolds not redistricted since 1901. 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. 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 . These three requirements are as follows: 1. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. 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. The state constitution required at least . 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. Justice Tom C. Clark wrote a concurring opinion. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. 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. Create your account. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. We are advised that States can rationally consider . 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. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. Spitzer, Elianna. I feel like its a lifeline. Reynolds was a resident of Jefferson County, Alabama. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. 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. It called for a 106-member House and a 35-member Senate. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. [2] Of the forty-eight states then in the Union, only seven[a] twice redistricted even one chamber of their legislature following both the 1930 and the 1940 Censuses. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes. 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. The act was temporary and would only be put in place if the first plan was defeated by voters. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. 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. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. 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. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. 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. The constitution also provided for reapportionment to take place following each decennial census. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Voters in the states are represented by members of their state legislature. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. 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. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Legislators are elected by voters, not farms or cities or economic interests. Justice John Marshall Harlan dissented. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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). Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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. She has also worked at the Superior Court of San Francisco's ACCESS Center. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's 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 ruling favored Baker 6-to-2 and it was found that the Supreme Court, in fact, did hold the aforementioned right. State officials appealed, arguing that the existing and proposed reapportionment plans are constitutional, and that the district court lacked the power to order temporary reapportionment. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. These plans were to take effect in time for the 1966 elections. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. In this case, the context was with regard to State legislatures. In the landmark case of Reynolds v. Sims, which concerned representation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among the several states according to their respective numbers." 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. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . 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. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. [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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. What is Reynolds v. Only the Amendment process can do that. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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. The Crawford-Webb Act provided for a 106-member house of representatives (with each of the state's 67 counties having one representative by default and the remaining seats being allocated on the basis of population) and a 35-member state senate (with districts drawn to adhere to existing county lines). 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. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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 Courts remedy of temporary reapportionment was appropriate for purposes of the 1962 elections, and it allows for the reapportioned legislature a chance to find a permanent solution for Alabama. [13], In a 2015 Time Magazine survey of over 50 law professors, both Erwin Chemerinsky (Dean, UC Berkeley School of Law) and Richard Pildes (NYU School of Law) named Reynolds v. Sims the "best Supreme Court decision since 1960", with Chemerinsky noting that in his opinion, the decision made American government "far more democratic and representative."[1]. 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. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. 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. Argued November 13, 1963. 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. 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. Baker v. Carr. Oyez. She also has a Bachelor's of Science in Biological Sciences from California University. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. 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. It is of the essence of a democratic society, Chief Justice Warren wrote. Spitzer, Elianna. [4][5], On August 26, 1961, the plaintiffs in the suit, a group of voters residing in Jefferson County, Alabama, filed suit in the United States District Court for the Middle District of Alabama. 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. Chief Justice Earl Warren delivered the 8-1 decision. 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. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. The case of Reynolds v. Sims was ruled to be justiciable, which means that the legislative portion of the United States government had already voted on the issue regarding a similar which case, which renders the actual case to be moot, or not matter. Some states refused to engage in regular redistricting, while others enshrined county by county representation (Like the federal government does with state by state representation) in their constitutions. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. It established the precedent that felons are not allowed to vote.B.) 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. There must be a causal connection between the injury and the conduct brought before the court. 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.
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