Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11]. 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. All rights reserved. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Appellant's Claim: That the creation of voting districts is the sole responsibility of state legislatures with no appropriate role for federal courts. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. It gave . This violated his equal protection rights under the 14th Amendment. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Sims: Summary, Decision & Significance. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. The amendment failed. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. 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. 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. [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. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. 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. 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. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Warren held that "legislators represent people, not trees or acres. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? Harlan contended that the Supreme Court did not have the authority to interfere in local matters. 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. 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. v. Varsity Brands, Inc. sign . 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. 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. and its Licensors It went further to state that Legislators represent people, not trees or acres. 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. 100% remote. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. Click here to contact our editorial staff, and click here to report an error. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Within two years, the boundaries of legislative districts had been redrawn all across the nation. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. 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. 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. Even though most of that growth occurred in urban areas. - 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.''. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. 320 lessons. What case violated the Equal Protection Clause? The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. 24 chapters | The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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. The state appealed the decision to the Supreme Court. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. 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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. 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. Reynolds v. Sims. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. 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. To unlock this lesson you must be a Study.com Member. As a result, virtually every state legislature was . Reynolds v. Sims Significance, "legislators Represent People, Not Trees", The Census, Further Readings Appellant R. A. Reynolds Appellee M. O. Sims Appellant's Claim That representation in both houses of state legislatures must be based on population. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. Justice John Marshall Harlan dissented. Create your account. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. The history of the Equal Protection Clause has nothing to do with a States choice in how to apportion their legislatures. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Only the Amendment process can do that. 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. In 2016, the Supreme Court rejected a challenge to "one person, one vote" in Evenwel et al. The decision had a major impact on state legislatures, as many states had to change their system of representation. Let's say your county sent five representatives to the state legislature, just like your neighboring county. 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. 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.". Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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? Spitzer, Elianna. Argued November 13, 1963. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. 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. 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." [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. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. We are advised that States can rationally consider . Furthermore, the existing apportionment, and also, to a lesser extent, the apportionment under the Crawford-Webb Act, presented little more than crazy quilts, completely lacking in rationality, and could be found invalid on that basis alone. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. 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. 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. The case was named for M. O. Sims, one of the voters who brought the suit, and B. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. Chief Justice Earl Warren delivered the 8-1 decision. ThoughtCo. Requiring states to employ honest and good faith practices when creating districts. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. In order to be considered justiciable, a case must be considered to be more than just political in essence. In this case, the context was with regard to State legislatures. 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 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. 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. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. Reynolds was sentenced for polygamy In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. [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. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. Sounds fair, right? Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. It went further to state that Legislators represent people, not trees or acres. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. The Court then turned to the equal protection argument. 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 decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. 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. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . 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 Fourteenth Amendment guarantees equal protection under the law. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. 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. 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 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9].

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