Because this was a requirement of the Equal Protection Clause of the 14th Amendment. ThoughtCo. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. However, states should strive to create districts that offer representation equal to their population. States may have to balance representation based on population with other legislative goals like ensuring minority representation. Create your account. Requiring states to employ honest and good faith practices when creating districts. Sims: Summary, Decision & Significance. The 1901 Alabama Constitution provided for a house of representatives comprising no more than 105 members (with an exception provided for new counties, each of which would be entitled to at least one representative). It should also be superior in practice as well. Since population growth in the state over the next 60 years was uneven, the plaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . copyright 2003-2023 Study.com. The district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5], Oral argument was held on November 13, 1963. Elianna Spitzer is a legal studies writer and a former Schuster Institute for Investigative Journalism research assistant. It went further to state that Legislators represent people, not trees or acres. What amendment did Reynolds v Sims violate? Even though most of that growth occurred in urban areas. 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. Along with Baker v.Carr (1962) and Reynolds v. Sims (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. 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. Before the argument of Reynolds v. Sims was argued and heard by judges, a case known as Baker v. Carr received a ruling approximately two years beforehand. The decision of the District Court for the Middle District of Alabama is affirmed, and remanded. Create your account. Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. The ruling in Reynolds v. Sims led to the one person, one vote rule, which aids in making sure legislative districts are divided equally so individual voting rights are not violated. All other trademarks and copyrights are the property of their respective owners. It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. After 60 years of significant population growth, some areas of the State had grown in population far more than others. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. 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. The United States District Court for the Middle District of Alabama unlawfully drafted a temporary reapportionment plan for the 1962 election, overstepping its authority. Equal Protection as guaranteed by the 5th and 14th amendments require broadly that each person be treated equally in their voting power, but what equality means relies on a series of Supreme Court cases. 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. If the 14th Amendment rights of Alabama residents were being violated due to the unequally proportioned representatives in different legislative districts in Alabama. The district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. 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 was just one of 15 reapportionment cases the Court decided in June of 1964. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Voters in the states are represented by members of their state legislature. are hardly of any less significance for the present and the future. 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. Enrolling in a course lets you earn progress by passing quizzes and exams. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. Sounds fair, right? Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. The Court's decision was among the first to hold that the free exercise of religion is not absolute. They were based on rational state policy that took geography into account, according to the state's attorneys. Create an account to start this course today. The issues were: 1. Contractors of America v. Jacksonville, Parents Involved in Community Schools v. Seattle School District No. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. 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. The U.S. Supreme Court granted certiorari. 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. Apply today! 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. A likely (not speculative) injury was suffered by an individual, 2. Considering the case of Reynolds v. Sims, there were two main issues that needed to be addressed and decided by the court. City of Cleburne v. Cleburne Living Center, Inc. Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank, Board of Trustees of the University of Alabama v. Garrett, Nevada Department of Human Resources v. Hibbs, https://en.wikipedia.org/w/index.php?title=Reynolds_v._Sims&oldid=1142377374, United States electoral redistricting case law, United States One Person, One Vote Legal Doctrine, American Civil Liberties Union litigation, United States Supreme Court cases of the Warren Court, Creative Commons Attribution-ShareAlike License 3.0, Appeal from the United States District Court for the Middle District of Alabama. 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 district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. (2020, August 28). [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. The question in this case was whether Alabamas legislative apportionment scheme violated the Equal Protection Clause of the 14. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. Reynolds v. Sims: Summary, Decision & Significance Instructor: Kenneth Poortvliet Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time. At the end of July 1962, the district court reached a ruling. 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. 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. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution. Baker v. However, should an issue be ruled to be justiciable, this means that one branch of the government's jurisdiction is not able to be infringed upon by other branches of government. As we know that federal law is superior to that of the states. The state constitution required at least . Sims?ANSWERA.) Within two years, the boundaries of legislative districts had been redrawn all across the nation. Spitzer, Elianna. In 2016, the Supreme Court rejected a challenge to one person, one vote in Evenwel et al. Enrolling in a course lets you earn progress by passing quizzes and exams. It also insisted that this apportionment be conducted every 10 years. It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. Reynolds claimed that the population of many of the legislative districts in Alabama were experiencing considerable population growth, and that more representation was not assigned to these growing localities.
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