The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. 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 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. This meant the rule could be settled by the Supreme Court with some certainty. Even though most of that growth occurred in urban areas. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. To unlock this lesson you must be a Study.com Member. 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. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. Section 2. Sims: Summary, Decision & Significance. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. Create an account to start this course today. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. 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. 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. 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. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Justice John Marshall Harlan dissented. 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. 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 second plan was called the Crawford-Webb Act. This right, can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise.Alabama diluted the vote of some of its residents by failing to offer representation based on population. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. 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. In 1961, M.O. Amendment. 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." 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 history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Reynolds v. Sims (1964) - Rose Institute 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. Amendments Equal protection clause of the U.S constitution. 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. As a result, virtually every state legislature was . [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]. 100% remote. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. v. Abbott, Governor of Texas. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. The constitution also provided for reapportionment to take place following each decennial census. 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. 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. 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). - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Wesberry v. Sanders. Oyez. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. v. Abbott, Governor of Texas. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Justice John Harlan II wrote a dissenting opinion. 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. It also insisted that this apportionment be conducted every 10 years. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. The case was decided on June 15, 1964. 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. 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." ThoughtCo. It should also be superior in practice as well. Enrolling in a course lets you earn progress by passing quizzes and exams. Sounds fair, right? Earl Warren | chief justice of United States | Britannica The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. [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 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. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. Reynolds v. Sims | Teaching American History Because this was a requirement of the Equal Protection Clause of the 14. 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. It devised a reapportionment plan and passed an amendment providing for home rule to counties. 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. 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. 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. Click here to contact our editorial staff, and click here to report an error. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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 district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. The Alabama Constitution provided that there be only one state senator per county. 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. It went further to state that Legislators represent people, not trees or acres. 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. 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. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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 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). The Court's decision was among the first to hold that the free exercise of religion is not absolute. Reynolds v. United States | The First Amendment Encyclopedia The district court drafted a temporary re-apportionment plan for the 1962 election. A citizens vote should not be given more or less weight because they live in a city rather than on a farm, Chief Justice Warren argued. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. In this case, the context was with regard to State legislatures. It is known as the "one person, one vote" case. 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 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. They were based on rational state policy that took geography into account, according to the state's attorneys.
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