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. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. A likely (not speculative) injury was suffered by an individual, 2. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. Reynolds v. Sims: Supreme Court Case, Arguments, Impact. Reynolds v. Sims | June 15, 1964 Print Bookmark Case Font Settings Clone and Annotate. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. In Reynolds v. Sims (1964), the Court ruled that the issue presented to them was justiciable, which meant that Reynolds had standing and it was an issue that was not a purely political question. [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. It was also believed that the 14th Amendment rights of citizens were being violated due to the lack of apportioned representatives for each of the legislative districts. Amendment. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). It is of the essence of a democratic society, Chief Justice Warren wrote. What was the significance of Reynolds vs Sims? - WittyQuestion.com State senate districts must have roughly equal populations based on the principle of "one person, one vote". This system failed to take population size into account, leading to huge discrepancies between district . of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. - 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.''. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Section 2. Reynolds v. United States | The First Amendment Encyclopedia The constitution also provided for reapportionment to take place following each decennial census. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. These three requirements are as follows: 1. Whatever may be thought of this holding as a piece of political ideology -- and even on that score, the political history and practices of this country from its earliest beginnings leave wide room for debate -- I think it demonstrable that the Fourteenth Amendment does not impose this political tenet on the States or authorize this Court to do so. The 14th Amendment requires that a state government treat everyone equally under the law, and is often used by state citizens to sue their government for discrimination and unequal treatment. Reynolds was sentenced for polygamy It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . 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 - Significance, "legislators Represent People, Not Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. 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It established the precedent that felons are not allowed to vote.B.) 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. 100% remote. 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. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. 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. 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? State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. Wesberry v. Sanders. Oyez. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. [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. I would definitely recommend Study.com to my colleagues. Spitzer, Elianna. Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. 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. Chief Justice Earl Warren delivered the opinion of the court. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Sims: Summary, Decision & Significance. State officials appealed, arguing that Alabamas existing and proposed reapportionment plans are constitutional and that the District Court lacked the power to reapportion the Legislature itself. Create an account to start this course today. 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. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. Justices struck down three apportionment plans for Alabama that would have given more weight to voters in rural areas than voters in cities. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. Sounds fair, right? The district court had not erred in its finding that neither the Crawford-Webb Act or the 67-member plan could be used as a permanent reapportionment plan, the attorneys argued. Reynolds v. Sims 1964. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. 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. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. 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. 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. - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. if(document.getElementsByClassName("reference").length==0) if(document.getElementById('Footnotes')!==null) document.getElementById('Footnotes').parentNode.style.display = 'none'; Communications: Alison Graves Carley Allensworth Abigail Campbell Sarah Groat Caitlin Vanden Boom Reynolds v. Sims (1964) - U.S. Conlawpedia - GSU States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. 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. The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. 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. 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. Sims. I feel like its a lifeline. The District Court was correct to come to that holding and to reject the States proposed apportionment plans. copyright 2003-2023 Study.com. Reynolds believed that, due to the population growth in the county where he lived and what was. Reynolds v. Sims (1964) Case Summary. Santa Clara County v. Southern Pacific Railroad Co. Harper v. Virginia State Board of Elections, San Antonio Independent School District v. Rodriguez, Massachusetts Board of Retirement v. Murgia, New York City Transit Authority v. Beazer. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing states legislative apportionment cases. 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 existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. Dilution of a persons vote infringes on his or her right of suffrage. The decision in Wesberry, which concerned federal election districts, was based on Article I of the Constitution, which governs the federal legislative branch. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. What was the significance of the famous case Reynolds v. Sims? This way a way of reiterating the point, since the change in population occurred mainly in urban areas. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. The decision had a major impact on state legislatures, as many states had to change their system of representation. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. 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. The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. 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. 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. Argued November 13, 1963. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. v. Varsity Brands, Inc. Reynolds v. Sims | Teaching American History Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Reynolds v. Sims (1964) | The Rose Institute of State and Local Government Quiz & Worksheet - Reynolds v. Sims 1964 | Study.com Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. 1, Schuette v. Coalition to Defend Affirmative Action, Students for Fair Admissions v. President and Fellows of Harvard College, Personnel Administrator of Massachusetts v. Feeney, Mississippi University for Women v. Hogan. What is Reynolds v. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. Warren, joined by Black, Douglas, Brennan, White, Goldberg, This page was last edited on 2 March 2023, at 02:02. 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. The U.S. Supreme Court granted certiorari. 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). Reynolds v. Sims | Encyclopedia.com 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. However, states should strive to create districts that offer representation equal to their population. 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. As a result, virtually every state legislature was . The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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.". Reynolds v. Sims - Harvard University ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. Reynolds v. Sims - Case Summary and Case Brief - Legal Dictionary 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. The most relevant Supreme Court case is Reynolds v. Sims, 377 U.S. 533 (1964). The state argued that federal courts should not interfere in state apportionment. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." 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. Create your account. Numerous states had to change their system of representation in the state legislature. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch 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. Because this was a requirement of the Equal Protection Clause of the 14. 17.3 Politics in the United States - OpenStax 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. v. Abbott, Governor of Texas. 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."