The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. We are advised that States can rationally consider . In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. 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. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? The Court's decision in Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people. What case violated the Equal Protection Clause? 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. 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. 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. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. As a result of the decision, almost every state had to redraw its legislative districts, and power . Did the state of Alabama discriminate against voters in counties with higher populations by giving them the same number of representatives as smaller counties? Today's holding is that the Equal Protection Clause of the Fourteenth Amendment requires every State to structure its legislature so that all the members of each house represent substantially the same number of people; other factors may be given play only to the extent that they do not significantly encroach on this basic 'population' principle. Reynolds v. Sims. However, states should strive to create districts that offer representation equal to their population. To unlock this lesson you must be a Study.com Member. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. In Reynolds v. Sims (1964) the U.S. Supreme Court ruled that states must create legislative districts that each have a substantially equal number of voters to comply with the Equal Protection Clause of the Fourteenth Amendment. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. This system failed to take population size into account, leading to huge discrepancies between district . Section 1. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. 24 chapters | The district court further declared that the redistricting plans recently adopted by the legislature were unconstitutional. [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. Even though most of that growth occurred in urban areas. The Fourteenth Amendment guarantees equal protection under the law. 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. This ruling was so immediately impactful to state legislatures that there was an attempt to pass a constitutional amendment to allow states to have districts of varying populations. 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." The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. This system failed to take population size into account, leading to huge discrepancies between district . [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. Wesberry v. Sanders. Oyez. The act was temporary and would only be put in place if the first plan was defeated by voters. The case of Reynolds v. Sims was initially argued November 13, 1963, but a decision on this case was not reached until June 15, 1964. Attorneys representing the voters argued that Alabama had violated a fundamental principle when it failed to reapportion its house and senate for close to 60 years. He said that the decision evolved from the courts ruling in Gray v. Sanders that mandated political equality means one person one vote. Legislators are elected by voters, not farms or cities or economic interests." 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). Once you finish this lesson, you should be able to: Once you finish this lesson, you should be able to: Give the year that Reynolds v. All rights reserved. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. A likely (not speculative) injury was suffered by an individual, 2. The case was named for M. O. Sims, one of the voters who brought the suit, and B. Legislators are elected by voters, not farms or cities or economic interests. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. As a result, virtually every state legislature was . Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). 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! These plans were to take effect in time for the 1966 elections. What is Reynolds v. Without reapportionment, multiple districts were severely underrepresented. copyright 2003-2023 Study.com. 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. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. This case overturned a previous ruling or rulings, These being New Jersey, Massachusetts, New Hampshire (, Alabama Legislative Black Caucus v. Alabama, List of United States Supreme Court cases, volume 377, "The Best Supreme Court Decisions Since 1960", "Reapportionments of State Legislatures: Legal Requirement", "B. In response, the Court then applied the one person, one vote rule for redistricting and reapportionment issues. 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. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. Create your account. 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. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. What amendment did Reynolds v Sims violate? 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. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. Baker v. Carr: Supreme Court Case, Arguments, Impact, The Civil Rights Act of 1866: History and Impact, Shaw v. Reno: Supreme Court Case, Arguments, Impact, What Is A Poll Tax? Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Sounds fair, right? The decision had a major impact on state legislatures, as many states had to change their system of representation. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. 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. v. Abbott, Governor of Texas. Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. 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. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. Enrolling in a course lets you earn progress by passing quizzes and exams. Alabamas states constitution which was adopted in 1900 specified that states legislative districts be apportioned according to population for the basis of representation. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." Yes. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. 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. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. The state constitution of Alabama mandated that, every ten years, populations of all the legislative districts in the state should be examined and appropriate representation, considering population, should be assigned to each of the legislative districts statewide, in accordance with the census that is taken once per decade. 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. Reynolds believed that, due to the population growth in the county where he lived and what was. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. The Court's decision was among the first to hold that the free exercise of religion is not absolute. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. 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.
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