TLDR: "That's just your opinion, man Earl." Sims and Baker v.Carr said that state governments couldn't simply iterate the form of the federal government (one chamber apportioned by population, one chamber apportioned by existing political divisions), that state legislatures and every lower level had to be one-person-one-vote-uber-alles.As Justice Frankfurter pointed out in dissent in Baker . These three requirements are as follows: 1. It devised a reapportionment plan and passed an amendment providing for home rule to counties. 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. But say 20 years later, your county tripled in population but still had the same number of representatives as your neighbor. 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. Reynolds was a resident of Jefferson County, Alabama. Sims: Summary, Decision & Significance. QUESTIONWhat was the significance of the famous case Reynolds v. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. The Crawford-Webb Act provided 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 35-member state senate (with districts drawn to adhere to existing county lines). The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. v. Varsity Brands, Inc. The ruling in Reynolds v. Sims led to the one person, one vote rule, which aids in making sure legislative districts are divided equally so individual voting rights are not violated. 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. 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. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. Enrolling in a course lets you earn progress by passing quizzes and exams. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14th Amendment by weighing some votes higher than another? 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. Cruzan v. Director, Missouri Dept. 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. Click here to contact our editorial staff, and click here to report an error. This violated his equal protection rights under the 14th Amendment. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. 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 The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Spitzer, Elianna. Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. [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]. 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. [8] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[9]. To read more about the impact of Reynolds v. Sims click here. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. As we know that federal law is superior to that of the states. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. The case was decided on June 15, 1964. 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. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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. 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. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. [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]. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. 24 chapters | This way a way of reiterating the point, since the change in population occurred mainly in urban areas. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. At the end of July 1962, the district court reached a ruling. 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. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. 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. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . The state constitution required at least . External Relations: Moira Delaney Hannah Nelson Caroline Presnell ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Find the full text here.. [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. No. 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. 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. 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 and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. Requiring states to employ honest and good faith practices when creating districts. 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. 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. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. 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. 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. 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. What is Reynolds v. Star Athletica, L.L.C. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. 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. 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. It gave . Spitzer, Elianna. 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 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 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. For example, say the House of Representative changed their floor rules and a representative challenged the rules in court. 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. It is known as the "one person, one vote" case. It also insisted that this apportionment be conducted every 10 years. 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. Argued November 13, 1963. In an 8-to-1 ruling, it was found that the case of Reynolds v. Sims was justiciable, or had standing, because it was not purely of political concern. All rights reserved. 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. 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. Reynolds v. Sims is a well-known court case which made its way through district courts and ended up being heard by the United States Supreme Court. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. A likely (not speculative) injury was suffered by an individual, 2. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al", "Reapportionment--I "One Man, One Vote" That's All She Wrote! 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. In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Sims. 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.