Chief Justice Earl Warren delivered the 8-1 decision. Lines dividing electoral districts had resulted in dramatic population discrepancies among the districts. The Court's decision was among the first to hold that the free exercise of religion is not absolute. The plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. The case was named for M. O. Sims, one of the voters who brought the suit, and B. This is called the political question doctrine, and is invoked if the issue is such that a hearing by the courts will not settle the issue due to its purely political nature. Accordingly, the Equal Protection Clause demands that both houses in a States bicameral legislature must be apportioned on a population basis. 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. 100% remote. Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. It doesn't violate Reynolds.. because Reynolds.. doesn't apply to the Senate. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Click here to contact us for media inquiries, and please donate here to support our continued expansion. It established the precedent that felons are not allowed to vote.B.) The court also ruled in Wesberry v. Sanders that when votes weigh more in one district than another, the idea of a representative democracy is undermined. There must be a causal connection between the injury and the conduct brought before the court. 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. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. During the same legislative session, lawmakers also adopted the Crawford-Webb Act, a temporary measure that provided for reapportionment in the event that the constitutional amendment was defeated by voters or struck down by the courts. 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 district courts judgement was affirmed. 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 decision had a major impact on state legislatures, as many states had to change their system of representation. https://www.thoughtco.com/reynolds-v-sims-4777764 (accessed March 4, 2023). In Reynolds v. Sims, the Court was presented with two issues: The Supreme Court held that the apportionment issue concerning Alabama's legislature was justiciable. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. ThoughtCo. It gave . The court held that Once the geographical boundaries of a district are set, all who participate in that election have an equal vote no matter their sex, race, occupation, or geographical unit. I would definitely recommend Study.com to my colleagues. 2. In this case, the context was with regard to State legislatures. Spitzer, Elianna. 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 . Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. 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. Neither the 67-member plan or the Crawford-Webb Act were sufficient remedies to end the discrimination that unequal representation had created. "Reynolds v. Sims: Supreme Court Case, Arguments, Impact." When the Court applied this rule to Alabama's then-current apportionment, it ruled that their unequal apportionment violated the voters' equal protection rights protection under the 14th Amendment. State representatives represent people, not geographic regions. 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. The state appealed the decision to the Supreme Court. These individuals were voters and taxpayers from this locality. Voters in the states are represented by members of their state legislature. After Reynolds v. Sims, districts were redrawn so that they would include equal numbers of voters. ThoughtCo, Aug. 28, 2020, thoughtco.com/reynolds-v-sims-4777764. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. 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. Reynolds v. Sims and Baker v. Carr, have become known as the cases that established "one person, one vote." Along with Baker v. Carr (1962) and Wesberry v. 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 existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. 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. It should also be superior in practice as well. Ballotpedia features 395,557 encyclopedic articles written and curated by our professional staff of editors, writers, and researchers. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Reynolds v. Sims is a famous legal case that reached the United States Supreme Court in 1964. The state argued that federal courts should not interfere in state apportionment. All other trademarks and copyrights are the property of their respective owners. 320 lessons. Find the full text here.. This is the issue the Supreme Court faced in Reynolds v. Sims (1964). She also has a Bachelor's of Science in Biological Sciences from California University. 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. 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. 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. Research: Josh Altic Vojsava Ramaj Create an account to start this course today. Create your account. A citizens vote should not be given more or less weight because they live in a city rather than on a farm, Chief Justice Warren argued. Requiring states to employ honest and good faith practices when creating districts. He stated that the court had gone beyond its own necessity ties in creating and establishing a new equal proportion legislative apportionment scheme. Legislators are elected by voters, not farms or cities or economic interests." 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. Simply because one of Alabamas apportionment plans resembled the Federal set up of a House comprised of representatives based on population, and a Senate comprised of an equal number of representatives from each State does not mean that such a system is appropriate in a State legislature. It should also be superior in practice as well. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Justice Harlan argued that the majority had ignored the legislative history of the Fourteenth Amendment. 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." Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. 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. The state constitution required at least . Justice Potter Stewart also issued a concurring opinion, in which he argued that while many of the schemes of representation before the court in the case were egregiously undemocratic and clearly violative of equal protection, it was not for the Court to provide any guideline beyond general reasonableness for apportionment of districts. Since under neither the existing apportionment provisions nor either of the proposed plans was either of the houses of the Alabama Legislature apportioned on a population basis, the District Court correctly held that all three of these schemes were constitutionally invalid. 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. Prior to the case, numerous state legislative chambers had districts containing unequal populations; for example, in the Nevada Senate, the smallest district had 568 people, while the largest had approximately 127,000 people. The political question doctrine states that, when it is invoked, that a case is unable to be settled in the court of law if the issue it addresses stems from an essence that is merely political in its nature. 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. 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. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. 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The Equal Protection Clause of the 14th Amendment mandates that individual states work to provide equal protection, which means that governing occurs without bias and that lone individual differences are unimportant when considering citizens. Even though most of that growth occurred in urban areas. The second plan was called the Crawford-Webb Act. 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. [1], The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. I feel like its a lifeline. Significance: Reynolds v. Sims is famous for, and has enshrined, the "one person, one vote" principle. Section 2. Whether the apportionment of Alabama's representative caused the voters to be unequally represented to such a degree that their 14th Amendment rights were violated. Spitzer, Elianna. At the end of July 1962, the district court reached a ruling. This meant the rule could be settled by the Supreme Court with some certainty. This system failed to take population size into account, leading to huge discrepancies between district . The Court's discussion there of the significance of the Fifteenth Amendment is fully applicable here with respect to the Nineteenth Amendment as well. To read more about the impact of Reynolds v. Sims click here. 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. 24 chapters | "[4][5], In July 1962, the state legislature approved a proposed constitutional amendment providing for a 106-member house of representatives (with each of the state's 67 counties having one representative by default and the remaining seats being allocated on the basis of population) and a 67-member state senate (with one senator from each county). 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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. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Decision of One Person, One Vote Court Case, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. 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