Legislators are elected by voters, not farms or cities or economic interests. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. 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. The district courts judgement was affirmed. 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. 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. 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. We are told that the matter of apportioning representation in a state legislature is a complex and many-faceted one. Because this was a requirement of the Equal Protection Clause of the 14. 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. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. Research: Josh Altic Vojsava Ramaj [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. 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. The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. I would definitely recommend Study.com to my colleagues. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. 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. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Legislators are elected by voters, not farms or cities or economic interests. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). All of these are characteristics of a professional legislature except meets biannually. At that time the state legislature consisted of a senate with 35 members and a house of representatives with 106 members. copyright 2003-2023 Study.com. Policy: Christopher Nelson Caitlin Styrsky Molly Byrne Katharine Frey Jimmy McAllister Samuel Postell v. Varsity Brands, Inc. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. Amendments Equal protection clause of the U.S constitution. [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. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. 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. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. Among the more extreme pre-Reynolds disparities[10] claimed by Morris K. Udall: The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. 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. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. - Definition & History, Homo Sapiens: Meaning & Evolutionary History, What is Volcanic Ash? 24 chapters | For the Senate, each county gets two representatives, regardless of size. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Mullane v. Central Hanover Bank & Trust Co. Cleveland Board of Education v. Loudermill, Cruzan v. Director, Missouri Department of Health, Cumming v. Richmond County Board of Education, Sipuel v. Board of Regents of the University of Oklahoma, Davis v. County School Board of Prince Edward County, Griffin v. County School Board of Prince Edward County, Green v. County School Board of New Kent County, United States v. Montgomery County Board of Education, Alexander v. Holmes County Board of Education, Swann v. Charlotte-Mecklenburg Board of Education. 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. [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. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. As a result, virtually every state legislature was . Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Reynolds v. Sims 1964. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. It should also be superior in practice as well. [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]. The Court's decision was among the first to hold that the free exercise of religion is not absolute. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. These three requirements are as follows: 1. 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. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. As we know that federal law is superior to that of the states. It gave . What case violated the Equal Protection Clause? Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation. 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)] 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. Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities. It established the precedent that felons are not allowed to vote.B.) 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 decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. 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 Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. At the end of July 1962, the district court reached a ruling. 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. Spitzer, Elianna. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. Along with Baker v. Carr (1962) and Wesberry v. QUESTIONWhat was the significance of the famous case Reynolds v. To unlock this lesson you must be a Study.com Member. What amendment did Reynolds v Sims violate? 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. 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 . As a result of the decision, almost every state had to redraw its legislative districts, and power . 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. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Requiring states to employ honest and good faith practices when creating districts. It also insisted that this apportionment be conducted every 10 years. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. 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. - 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.''. Yet Another Question demonstrating how people so fundamentally misunderstand the United 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. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. 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. All rights reserved. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. All other trademarks and copyrights are the property of their respective owners. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Reynolds v. Sims, 377 U.S. 533 (1964), was a landmark United States Supreme Court case in which the Court ruled that the electoral districts of state legislative chambers must be roughly equal in population. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. Baker v. Sims. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. 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. Chief Justice Earl Warren delivered the opinion of the court. The constitution also provided for reapportionment to take place following each decennial census. 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. The dissent strongly accused the Court of repeatedly amending the Constitution through its opinions, rather than waiting for the lawful amendment process: "the Court's action now bringing them (state legislative apportionments) within the purview of the Fourteenth Amendment amounts to nothing less than an exercise of the amending power by this Court." 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.