Further stating that the equal protection clause wasnot designed for representatives whom represent all citizens to be greater or less. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. The constitution also provided for reapportionment to take place following each decennial census. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. Instead, the issues were being left open due to the Court's reluctance to avoid the problem. 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. 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. [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. 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 . Some states refused to engage in regular redistricting, while others enshrined county by county representation (Like the federal government does with state by state representation) in their constitutions. 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. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. The Alabama legislature convened that month for an extraordinary session. They adopted two reapportionment plans that would take effect after the 1966 election. 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. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Reynolds v. Sims and Baker v. Carr have been heralded as the most important cases of the 1960s for their effect on legislative apportionment. 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 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. Its like a teacher waved a magic wand and did the work for me. 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. Reynolds v. Sims, 377 U.S. 533 (1964) Significance: Both houses of a bicameral state legislature must be apportioned substantially according to population. Legislators are elected by voters, not farms or cities or economic interests." Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . Despite claims of the importance of "equality," the language and history of the Fourteenth Amendment suggest that it should not prevent states from developing individual democratic processes. Create an account to start this course today. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. When Reynolds v. Sims was argued, it had been over sixty years since their last update to the apportionment of elected representatives. Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. The constitution established a state senate comprising no more than 35 members, with the actual number of senators falling between one-fourth and one-third of the number of state representatives. On this Wikipedia the language links are at the top of the page across from the article title. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. 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." [5] In New Hampshire the state constitutions, since January 1776, had always called for the state senate to be apportioned based on taxes paid, rather than on population. Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. Baker v. Carr. Oyez. Argued November 13, 1963. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? Reynolds believed that, due to the population growth in the county where he lived and what was. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. The Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. She has also worked at the Superior Court of San Francisco's ACCESS Center. Amendment. 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 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. At the end of July 1962, the district court reached a ruling. External Relations: Moira Delaney Hannah Nelson Caroline Presnell Interns wanted: Get paid to help ensure that every voter has unbiased election information. 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. Click here to contact us for media inquiries, and please donate here to support our continued expansion. Before the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, as a counterbalance to towns and cities. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. The court in an 8-1 decision struck down Alabamas apportionment scheme as unconstitutional. 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. The Equal Protection Clause, which was upheld by the ruling in Reynolds v. Sims, states that all legislative districts of individual states should be uniform in population size. 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. This inherently nullifies the votes of some citizens and even weighted some more than the other since the distracting scheme did not reflect their population. As a result, virtually every state legislature was . State senate districts must have roughly equal populations based on the principle of "one person, one vote". To unlock this lesson you must be a Study.com Member. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. The state appealed the decision to the Supreme Court. 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. All of these are characteristics of a professional legislature except meets biannually. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. What resulted from the supreme court decisions in Baker v. Carr. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in the nation. 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. 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. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. 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. The Fourteenth Amendment guarantees equal protection under the law. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. Section 1. It called for a 106-member House and a 35-member Senate. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. 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. 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. 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. 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.