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. 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. copyright 2003-2023 Study.com. Justice John Marshall Harlan dissented. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. Sims, David J. Vann (of Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. v. Abbott, Governor of Texas. It should be noted that Alabamas legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? 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. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. Sims. State senate districts must have roughly equal populations based on the principle of "one person, one vote". All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. The districts adhered to existing county lines. 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 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. On August 26, 1961 residents and taxpayers of Jefferson County, Alabama, joined in a lawsuit against the state. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. Spitzer, Elianna. 'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . - Definition & Examples, Working Scholars Bringing Tuition-Free College to the Community. 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. [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 is famous for, and has enshrined, the one person, one vote principle. The constitution also provided for reapportionment to take place following each decennial census. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. However, states should strive to create districts that offer representation equal to their population. 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. 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. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. Baker v. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. Click here to contact our editorial staff, and click here to report an error. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. Enrolling in a course lets you earn progress by passing quizzes and exams. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? The first plan, which became known as the 67-member plan, called for a 106-member House and a 67-member Senate. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. Within two years, the boundaries of legislative districts had been redrawn all across the nation. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. [13], In a 2015 Time Magazine survey of over 50 law professors, both Erwin Chemerinsky (Dean, UC Berkeley School of Law) and Richard Pildes (NYU School of Law) named Reynolds v. Sims the "best Supreme Court decision since 1960", with Chemerinsky noting that in his opinion, the decision made American government "far more democratic and representative."[1]. 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Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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. 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. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. The ones that constitutional challenges. However, allegations of State Senates being redundant arose, as all states affected retained their state senates, with state senators being elected from single-member districts, rather than abolishing the upper houses, as had been done in 1936 in Nebraska[b] (and in the provinces of Canada), or switching to electing state senators by proportional representation from several large multi-member districts or from one statewide at-large district, as was done in Australia. Amendment by weighing some votes higher than another? Can a state use a reapportionment plan that ignores significant shifts in population? 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. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection. I feel like its a lifeline. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Reynolds v. Sims. 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. The Fourteenth Amendment guarantees equal protection under the law. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. copyright 2003-2023 Study.com. Cruzan v. Director, Missouri Dept. For instance, South Carolina had elected one state senator from each county. After 60 years of significant population growth, some areas of the State had grown in population far more than others. Baker v. Carr held that federal courts are able to rule on the constitutionality of the relative size of legislative districts. The district court drafted a temporary re-apportionment plan for the 1962 election. The court declared in Gary v. Sanders that the aim of one person, one vote should be tried to achieved. - 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.''. All rights reserved. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. All other trademarks and copyrights are the property of their respective owners. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. It established the precedent that felons are not allowed to vote.B.) Reynolds v. Sims 1964. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. As we know that federal law is superior to that of the states. 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. O'Gorman & Young, Inc. v. Hartford Fire Insurance Co. Dobbs v. Jackson Women's Health Organization, Planned Parenthood of Central Missouri v. Danforth, City of Akron v. Akron Center for Reproductive Health, Thornburgh v. American College of Obstetricians & Gynecologists, Ohio v. Akron Center for Reproductive Health, Ayotte v. Planned Parenthood of Northern New England. 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. Jefferson County, with a population of more than 600,000 received seven seats in the Alabama House of Representatives and one seat in the Senate, while Bullock County, with a population of more than 13,000 received two seats in the Alabama House of Representatives and one seat in the Senate. The federal district court, unsatisfied with Alabamas proposals to remedy the representation problem, ordered temporary. Because this was a requirement of the Equal Protection Clause of the 14. Numerous states had to change their system of representation in the state legislature. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. The Court said that these cases defeat the required element in a non-justiciable case that the Court is unable to settle the issue. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. There are three basic requirements for one to have legal standing in a court case when attempting to file a lawsuit, according to the laws governing the United States of America. 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. 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. Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964). Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause. The Senate's Make-up is determined by the constitution and SCOTUS doesn't have the authority to change it. 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. Section 1. Reynolds was sentenced for polygamy In 1961, M.O. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. Shortly after the Supreme Court handed down its decision in Baker v. Carr in March of 1962, under pressure from the federal district court that was still considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. http://caselaw.findlaw.com/us-supreme-court/377/533.html, Wesberry v. Sanders. Oyez. 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. 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 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. 2d 506 (1964), in which the U.S. Supreme Court established the principle of one person, one vote based on the equal protection clause of the Fourteenth Amendment . Reynolds believed that, due to the population growth in the county where he lived and what was written in the state constitution of Alabama, there were not enough elected officials acting as representatives for the area.
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