She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. 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. 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. 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. 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. This is called the political question doctrine, and is invoked if the issue is such that a hearing by the courts will not settle the issue due to its purely political nature. This inherently nullifies the votes of some citizens and even weighted some more than the other since the distracting scheme did not reflect their population. I feel like its a lifeline. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. After 60 years of significant population growth, some areas of the State had grown in population far more than others. In order to be considered justiciable, a case must be considered to be more than just political in essence. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. For instance, South Carolina had elected one state senator from each county. 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. Senator Everett Dirksen of Illinois led a fight to pass a constitutional amendment allowing legislative districts based on land area, similar to the United States Senate. 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. Create an account to start this course today. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. What resulted from the supreme court decisions in Baker v. Carr. 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. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 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. 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. Just because an issue is deemed to be justiciable in the court of law, does not mean that a case is made moot by the act of voting. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." Legislators are elected by voters, not farms or cities or economic interests." The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. 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. 23. Ratio variances as great as 41 to 1 from one senatorial district to another existed in the Alabama Senate (i.e., the number of eligible voters voting for one senator was in one case 41 times the number of voters in another). Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? The U.S. Supreme Court granted certiorari. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. Create your account. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. 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. The amendment failed. 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. 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. 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The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. Only the Amendment process can do that. State senate districts must have roughly equal populations based on the principle of "one person, one vote". Argued November 13, 1963. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. 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. 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. It should also be superior in practice as well. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." Chief Justice Earl Warren delivered the 8-1 decision. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Amendments Equal protection clause of the U.S constitution. 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. 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. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Amendment by weighing some votes higher than another? Enrolling in a course lets you earn progress by passing quizzes and exams. 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. Warren held that "legislators represent people, not trees or acres. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. Let's say your county sent five representatives to the state legislature, just like your neighboring county. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. [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. State representatives represent people, not geographic regions. 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. Enrolling in a course lets you earn progress by passing quizzes and exams. It devised a reapportionment plan and passed an amendment providing for home rule to counties. Along with Baker v.Carr (1962) and Reynolds v. Sims (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. 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. [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 14th Amendments Equal protection clause of the U.S constitution. copyright 2003-2023 Study.com. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, 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, English Common Law System: Definition & History, Jeremy Bentham: Biography, Theory & Ethics, Schedule of Drugs: Classification & Examples, What are Zero Tolerance Laws & Policies? The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. Acknowledging the Court's long standing desire to stay away from the political power struggles within the state governments, the Court noted that since its decision in Baker v. Carr, there have been several cases filed across the country regarding the dilution of voters' rights due to inequitable apportionment. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas. Apply today! The state constitution of Alabama mandated that, every ten years, populations of all the legislative districts in the state should be examined and appropriate representation, considering population, should be assigned to each of the legislative districts statewide, in accordance with the census that is taken once per decade. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. It is known as the "one person, one vote" case. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. 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. 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. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). External Relations: Moira Delaney Hannah Nelson Caroline Presnell 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. 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. 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. 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 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 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. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. Along with Baker v. Carr (1962) and Wesberry v. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? The state argued that federal courts should not interfere in state apportionment. Without reapportionment, multiple districts were severely underrepresented. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. The U.S. Constitution undeniably protects the right to vote. Creating fair and effective representation is the main goal of legislative reapportionment and, as a result, the Equal Protection Clause guarantees the "opportunity for equal participation by all voters in the election of state legislators.". 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 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. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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 said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. This violated his equal protection rights under the 14th Amendment. Cruzan v. Director, Missouri Dept. 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 was sentenced for polygamy - 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 believed that, due to the population growth in the county where he lived and what was written in the state constitution of Alabama, there were not enough elected officials acting as representatives for the area. 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. 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. "[4][5], In July 1962, the state legislature approved a proposed constitutional amendment providing 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 67-member state senate (with one senator from each county). Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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.