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The constitution required that no county be divided between two senatorial districts and that no district comprise two or more counties not contiguous to one another. These individuals were voters and taxpayers from this locality. The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote." We hold that, as a basic constitutional standard, the Equal Protection Clause requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis. You have more people now, pay more in taxes and have more issues that need representation, so shouldn't you get more representatives? The Fourteenth Amendment guarantees equal protection under the law. It is known as the "one person, one vote" case. 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. 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. States may have to balance representation based on population with other legislative goals like ensuring minority representation. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. 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. It is of the essence of a democratic society, Chief Justice Warren wrote. In addition, the majority simply denied the argument that states were permitted to base their apportionment structures upon the Constitution itself, which requires two senators from each state despite substantially unequal populations among the states. After 60 years of significant population growth, some areas of the State had grown in population far more than others. Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, League of United Latin American Citizens v. Perry, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. Find the full text here.. 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). Harlan contended that the Supreme Court did not have the authority to interfere in local matters. As a result of the decision, almost every state had to redraw its legislative districts, and power shifted from rural to urban areas. [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. The residents alleged that this disparity in representation deprived voters of equal protection under the Fourteenth Amendment. [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. 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. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. Post-Reynolds, a number of states had to change their apportionment plans to take population into account. 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. Even though most of that growth occurred in urban areas. It went further to state that Legislators represent people, not trees or acres. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. Operations: Meghann Olshefski Mandy Morris Kelly Rindfleisch 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. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. Yes. 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. The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. 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. She has also worked at the Superior Court of San Francisco's ACCESS Center. What is Reynolds v. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws. 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. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. This system failed to take population size into account, leading to huge discrepancies between district . Senator Everett Dirksen of Illinois led a fight to pass a constitutional amendment allowing legislative districts based on land area, similar to the United States Senate. Reynolds is frequently ranked as one of the greatest Supreme Court decisions of the modern era.[1]. Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. 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. 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. At the end of July 1962, the district court reached a ruling. It went further to state that Legislators represent people, not trees or acres. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. The state argued that federal courts should not interfere in state apportionment. 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. 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. Tech: Matt Latourelle Nathan Bingham Ryan Burch Kirsten Corrao Beth Dellea Travis Eden Tate Kamish Margaret Kearney Eric Lotto Joseph Sanchez. Its like a teacher waved a magic wand and did the work for me. 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. But when the right to vote at any election for the choice of electors for President and Vice-President of the United States, Representatives in Congress, the Executive and Judicial officers of a State, or the members of the Legislature thereof, is denied to any of the male inhabitants of such State, being twenty-one years of age, and citizens of the United States, or in any way abridged, except for participation in rebellion, or other crime, the basis of representation therein shall be reduced in the proportion which the number of such male citizens shall bear to the whole number of male citizens twenty-one years of age in such State. Justice John Harlan II wrote a dissenting opinion. In 1961, M.O. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Reynolds claimed that the meaning of the article requires a reapportionment every time the census is taken. However, states should strive to create districts that offer representation equal to their population. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. 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. QUESTIONWhat was the significance of the famous case Reynolds v. All rights reserved. It should also be superior in practice as well. The districts adhered to existing county lines. Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. Reynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Legislative districts may deviate from strict population equality only as necessary to give representation to political subdivisions and provide for compact districts of contiguous territory. 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. As a result of the decision, almost every state had to redraw its legislative districts, and power . Interns wanted: Get paid to help ensure that every voter has unbiased election information. Reynolds v. Sims is a 1964 Supreme Court case holding that the Equal Protection Clause of the Fourteenth Amendment requires seats in a state legislature to be apportioned so that one vote equals one person residing in each state legislative district. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. 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. 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. Chief Justice Warren acknowledged that reapportionment plans are complex and it may be difficult for a state to truly create equal weight amongst voters. Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court ruled to correct what it considered egregious examples of malapportionment; these were serious enough to undermine the premises underlying republican government. 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. 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 . Legal standing requires three criteria, which are an actual injury, a connection between the injured party and another source, and the opportunity for redressability. As a result, virtually every state legislature was . Requiring states to employ honest and good faith practices when creating districts. Because this was a requirement of the Equal Protection Clause of the 14. Cruzan v. Director, Missouri Dept. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. Explain the significance of "one person, one vote" in determining U.S. policy; Discuss how voter participation affects politics in the United States; . Both the Crawford-Webb Act and the 67-member plan were in line with Alabama's state constitution, the attorneys argued in their brief. Spitzer, Elianna. --Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[11].