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. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. Justices for the Court: Hugo L. Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Chief Justice Earl Warren, Byron R. White. 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. and its Licensors This way a way of reiterating the point, since the change in population occurred mainly in urban areas. Reynolds, and the citizens who banded together with him, believed that the lack of update in the apportioned representatives violated the Alabama state constitution since representatives were supposed to be updated every ten years when a census was completed. They were based on rational state policy that took geography into account, according to the state's attorneys. [12] He warned that: [T]he forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. 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. For the Senate, each county gets two representatives, regardless of size. 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. 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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. [2], Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. The issues were: 1. 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. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. Create your account. She also has a Bachelor's of Science in Biological Sciences from California University. In order to be considered justiciable, a case must be considered to be more than just political in essence. The ones that constitutional challenges. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. He also alleged that by not doing so, the state was denying the voters and residents of his country their full representation under Alabama law, which violated their equal protection rights found in the 14th Amendment. The districts adhered to existing county lines. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. 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. [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]. 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. 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. 24 chapters | 2. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . In previous cases, the Supreme Court ruled that any state reapportionment and redistricting disputes were non-justiciable and should be left to state legislatures as purely political questions in which the federal courts should not interfere. Dilution of a persons vote infringes on his or her right of suffrage. Justice John Harlan II wrote a dissenting opinion. 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. 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 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. This system failed to take population size into account, leading to huge discrepancies between district . 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. 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. Justice Potter Stewart also issued a concurring opinion, in which he argued that while many of the schemes of representation before the court in the case were egregiously undemocratic and clearly violative of equal protection, it was not for the Court to provide any guideline beyond general reasonableness for apportionment of districts. All other trademarks and copyrights are the property of their respective owners. It called for a 106-member House and a 35-member Senate. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Because the number of representatives for each district remained the same over those 60 years, some voters in the State had a greater voice in government than others. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 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 Reynolds was sentenced for polygamy 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 residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. Chief Justice Earl Warren delivered the opinion of the court. What case violated the Equal Protection Clause? Reynolds alleged that Jefferson County had grown considerably while other counties around it hadn't, which created an unequal apportionment since Jefferson County had the same number of representatives as the other counties. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. 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. 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To read more about the impact of Reynolds v. Sims click here. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. All Rights Reserved 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. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . 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. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Along with Baker v. Carr (1962) and Wesberry v. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. 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. It went further to state that Legislators represent people, not trees or acres. are hardly of any less significance for the present and the future. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? In this case, the context was with regard to State legislatures. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. Equal Protection as guaranteed by the 5th and 14th amendments require broadly that each person be treated equally in their voting power, but what equality means relies on a series of Supreme Court cases. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. 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. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. The amendment failed. [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. The U.S. Supreme Court granted certiorari. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. [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. It was also believed that the 14th Amendment rights of citizens were being violated due to the lack of apportioned representatives for each of the legislative districts. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. This system failed to take population size into account, leading to huge discrepancies between district . 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. copyright 2003-2023 Study.com. Other articles where Reynolds v. Sims is discussed: Baker v. Carr: precedent, the court held in Reynolds v. Sims (1964) that both houses of bicameral legislatures had to be apportioned according to population. v. Abbott, Governor of Texas. 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. All other trademarks and copyrights are the property of their respective owners. The act was temporary and would only be put in place if the first plan was defeated by voters. 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.
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