Create your account. In July 1962, the United States District Court for the Middle District of Alabama acknowledged the changes in Alabamas population and noted that the state legislature could legally reapportion seats based on population, as was required under Alabamas state constitution. 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. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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 U.S. Constitution undeniably protects the right to vote. All other trademarks and copyrights are the property of their respective owners. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. 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 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 was sentenced for polygamy 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. sign . Amendments Equal protection clause of the U.S constitution. What resulted from the supreme court decisions in Baker v. Carr. 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. 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. [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. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. Without reapportionment, multiple districts were severely underrepresented. The Court had already extended "one person, one vote" to all U.S. congressional districts in Wesberry v. Sanders (1964) a month before, but not to the Senate. 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. Sounds fair, right? Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. The Fourteenth Amendment guarantees equal protection under the law. 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 ones that constitutional challenges. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. 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. 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. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. 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. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. 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. 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. I feel like its a lifeline. That is, equal protection under the Fourteenth Amendment--which only applies to the states--guarantees that each citizen shall have equal weight in determining the outcome of state elections. Reynolds v. Sims. States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. 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 Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. 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. 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.". 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. 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. 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). Other articles where Reynolds v. Sims is discussed: Baker v. Carr: precedent, the court held in Reynolds v. Sims (1964) that both houses of bicameral legislatures had to be apportioned according to population. 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 case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. It went further to state that Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests. 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. Justice John Harlan II wrote a dissenting opinion. Legislators are elected by voters, not farms or cities or economic interests." Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Create your account. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. 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! As a result, virtually every state legislature was . Alabama denied its voters equal protection by failing to reapportion its legislative seats in light of population shifts. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. All of these are characteristics of a professional legislature except meets biannually. 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. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. 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. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. 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. I would definitely recommend Study.com to my colleagues. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. It is clear that 60 years of inaction on the Alabama Legislatures part has led to an irrational legislative apportionment plan. The district court drafted a temporary re-apportionment plan for the 1962 election. Amendment by weighing some votes higher than another? 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. The district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5], Oral argument was held on November 13, 1963. What is Reynolds v. All other trademarks and copyrights are the property of their respective owners. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. 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? 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. Simply because one of Alabamas apportionment plans resembled the Federal set up of a House comprised of representatives based on population, and a Senate comprised of an equal number of representatives from each State does not mean that such a system is appropriate in a State legislature. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. Reynolds v. Sims is famous for, and has enshrined, the one person, one vote principle. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. Can a state use a reapportionment plan that ignores significant shifts in population? In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. 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. 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 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. It established the precedent that felons are not allowed to vote.B.) 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. On this Wikipedia the language links are at the top of the page across from the article title. In Reynolds v. United States, 98 U.S. 145 (1879), the Supreme Court ruled unanimously that a federal law prohibiting polygamy did not violate the free exercise clause of the First Amendment. QUESTIONWhat was the significance of the famous case Reynolds v. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Create an account to start this course today. Reynolds believed that, due to the population growth in the county where he lived and what was. 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. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. 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. Amendment. Argued November 13, 1963. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Decided June 15, 1964 377 U.S. 533ast|>* 377 U.S. 533. . 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch The Court then turned to the equal protection argument. 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. 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. Wesberry v. Sanders. Oyez. Because of this principle, proper proportioning of representatives should exist in all legislative districts, to make sure that votes are about equal with the population of residents. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. 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. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. Section 1. The 1901 Alabama Constitution provided for a house of representatives comprising no more than 105 members (with an exception provided for new counties, each of which would be entitled to at least one representative). However, two years before the Reynolds case, in Baker v. Carr (1962), the Supreme Court ruled that a redistricting attempt by the Tennessee legislature was a justiciable issue because the issue dealt with the interpretation of a state law and not their political process. 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. 320 lessons. 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. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. The case of Reynolds v. Sims arose after voters in Birmingham, Alabama, challenged the apportionment of the Alabama Legislature; the Constitution of Alabama provided for one state senator per county regardless of population differences.