Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances? 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. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. To unlock this lesson you must be a Study.com Member. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. 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. 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. 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. Wesberry v. Sanders - Wikipedia REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Amendment. [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. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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." 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. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. Justice Tom C. Clark wrote a concurring opinion. 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. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. 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. [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. In this lesson, we will learn if a voter has a right to equal representation under the U.S. Constitution. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. What amendment did Reynolds v Sims violate? 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 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Reynolds v. Sims Summary & Significance - study.com Redistricting and the Supreme Court: The Most Significant Cases The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. 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. 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. The residents alleged that this disparity in representation deprived voters of equal protection under 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. 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. What was the Supreme Court decision in Reynolds v Sims quizlet? They were based on rational state policy that took geography into account, according to the state's attorneys. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. To unlock this lesson you must be a Study.com Member. 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. Reynolds v. Sims: Summary, Decision & Significance 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. Reynolds v. Sims, 377 U.S. 533 (1964) - Justia Law The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. What was the significance of the famous case Reynolds v. Sims? 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. Amendments Equal protection clause of the U.S constitution. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. The constitution established a state senate comprising no more than 35 members, with the actual number of senators falling between one-fourth and one-third of the number of state representatives. Baker v. Carr. Oyez. Reynolds v. Sims (1964) - U.S. Conlawpedia - GSU are hardly of any less significance for the present and the future. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. Voters in the states are represented by members of their state legislature. It should also be superior in practice as well. 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. 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. The state argued that federal courts should not interfere in state apportionment. 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. 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. The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. 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. Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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. Yes. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. As mentioned earlier in this lesson, the one person, one vote clause is applicable to the Equal Protection Clause because it was ruled that voting is a protected right of the citizens of Alabama, and all other states. one-person, one-vote rule | Wex - LII / Legal Information Institute The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. Reynolds v. Sims (1964) Case Summary. [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. 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. Wesberry v. Sanders. Oyez. 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 district courts judgement was affirmed. Spitzer, Elianna. 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. 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. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. The plaintiffs further argued that "since population growth in the state from 1900 to 1960 had been uneven, Jefferson and other counties were now victims of serious discrimination with respect to the allocation of legislative representation" (i.e., population variations between districts created situations in which the voters of a smaller district were entitled to the same representation in the legislature as the voters of larger districts; each district). [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. Click here to contact our editorial staff, and click here to report an error. The state appealed the decision to the Supreme Court. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . Argued November 13, 1963. The Court then turned to the equal protection argument. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. State senate districts must have roughly equal populations based on the principle of "one person, one vote". 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. copyright 2003-2023 Study.com. The Fourteenth Amendment guarantees equal protection under the law. Reynolds v. Sims | Encyclopedia.com It gave . Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." [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]. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. 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. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch Sims: Summary, Decision & Significance. Its like a teacher waved a magic wand and did the work for me. No. Reynolds v. Sims: Supreme Court Case, Arguments, Impact - ThoughtCo Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. We are advised that States can rationally consider . To read more about the impact of Reynolds v. Sims click here. 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. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. Reynolds v. Sims 1964. 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. 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. 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). The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation.
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