- 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.''. 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. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. Reynolds, along with several other people who were all residents, taxpayers and voters from Jefferson County in Alabama, filed a suit in Federal District Court challenging the apportionment of the Alabama state legislature. In this case, the context was with regard to State legislatures. 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 . Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, League of United Latin American Citizens v. Perry, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy. For instance, South Carolina had elected one state senator from each county. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. Amendment by weighing some votes higher than another? 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. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. 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 Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Thus his vote was diluted in value because the group of representatives from his state had no more influence than a county with half the population. M.O. 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 Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. The Court then turned to the equal protection argument. Sims?ANSWERA.) What amendment did Reynolds v Sims violate? Within two years, the boundaries of legislative districts had been redrawn all across the nation. 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. 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. Voters in the states are represented by members of their state legislature. A likely (not speculative) injury was suffered by an individual, 2. 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 was brought by a group of Alabama voter s who alleged that the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment to United States Constitution. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. The district court drafted a temporary re-apportionment plan for the 1962 election. 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. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Chappelle v. Greater Baton Rouge Airport Dist. 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. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. No. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. Reynolds v. Sims. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. 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. Learn about the Supreme Court case, Reynolds v. Sims. 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 state argued that federal courts should not interfere in state apportionment. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. To unlock this lesson you must be a Study.com Member. All other trademarks and copyrights are the property of their respective owners. Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. And in deciding the dispute, the Court applied the one-person one-vote rule, therefore holding that the districts were not equal in population size and should be reapportioned to ensure equal representation. The U.S. Constitution undeniably protects the right to vote. 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 . 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 question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. Chief Justice Earl Warren delivered the opinion of the court. v. Abbott, Governor of Texas. 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. 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. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. It called for a 106-member House and a 35-member Senate. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972Reynolds v. Sims - Significance, "legislators Represent People, Not Trees", The Census, Further Readings, Copyright 2023 Web Solutions LLC. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. v. Varsity Brands, Inc. 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. It gave . 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. This violated his equal protection rights under the 14th Amendment. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). She also has a Bachelor's of Science in Biological Sciences from California University. O'Gorman & Young, Inc. v. Hartford Fire Insurance Co. Dobbs v. Jackson Women's Health Organization, Planned Parenthood of Central Missouri v. Danforth, City of Akron v. Akron Center for Reproductive Health, Thornburgh v. American College of Obstetricians & Gynecologists, Ohio v. Akron Center for Reproductive Health, Ayotte v. Planned Parenthood of Northern New England. [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. 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? Baker v. Carr: Supreme Court Case, Arguments, Impact, The Civil Rights Act of 1866: History and Impact, Shaw v. Reno: Supreme Court Case, Arguments, Impact, What Is A Poll Tax? Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Research: Josh Altic Vojsava Ramaj 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. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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? Yes. 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 1. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. 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. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. All other trademarks and copyrights are the property of their respective owners. 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. 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. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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. Legislative districts may deviate from strict population equality only as necessary to give representation to political subdivisions and provide for compact districts of contiguous territory. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. Apply today! State representatives represent people, not geographic regions. 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. 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. We are advised that States can rationally consider . The Alabama Constitution provided that there be only one state senator per county. The amendment failed. of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. The districts adhered to existing county lines. Before a person can bring a suit against their government, he or she must have standing, which requires that: Once a person has standing, then the issue must be justiciable, which means that the issue before the court is not one of a purely political nature. Click here to contact our editorial staff, and click here to report an error. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. 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. City of Cleburne v. Cleburne Living Center, Inc. Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank, Board of Trustees of the University of Alabama v. Garrett, Nevada Department of Human Resources v. Hibbs, https://en.wikipedia.org/w/index.php?title=Reynolds_v._Sims&oldid=1142377374, United States electoral redistricting case law, United States One Person, One Vote Legal Doctrine, American Civil Liberties Union litigation, United States Supreme Court cases of the Warren Court, Creative Commons Attribution-ShareAlike License 3.0, Appeal from the United States District Court for the Middle District of Alabama. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. 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 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 district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. 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. Since under neither the existing apportionment provisions nor either of the proposed plans was either of the houses of the Alabama Legislature apportioned on a population basis, the District Court correctly held that all three of these schemes were constitutionally invalid. Reynolds v. Sims 1964. I feel like its a lifeline. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Because this was a requirement of the Equal Protection Clause of the 14. [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. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. These three requirements are as follows: 1. The case was decided on June 15, 1964. 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. [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 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. Legislators are elected by voters, not farms or cities or economic interests.