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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. Who Was The Attorney For Reynolds V Sims The Court goes beyond what this case requires by enforcing some form of one person, one vote principle. Ratio variances as great as 41 to 1 from one senatorial district to another existed in the Alabama Senate (i.e., the number of eligible voters voting for one senator was in one case 41 times the number of voters in another). The case was brought by a group of Alabama voter s who alleged that the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment to United States Constitution. Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. 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. She has been writing instructional content for an educational consultant based out of the greater Pittsburgh area since January 2020. 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. Justice Harlan argued that the majority had ignored the legislative history 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. 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. 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. The significance of the U.S. Supreme Court decisions in Baker v. Carr and Reynolds v. Sims is that the decisions established that legislatures must be apportioned according to the one-person, one-vote standard. The district courts judgement was affirmed. Definition and Examples, Current Justices of the U.S. Supreme Court, The Warren Court: Its Impact and Importance, What Is Majoritarianism? of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. 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. [2], Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Reynolds v. Sims (1964) | The Rose Institute of State and Local Government Sims: Summary, Decision & Significance. Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. 24 chapters | David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. A likely (not speculative) injury was suffered by an individual, 2. 320 lessons. Reynolds v. Sims 1964. Interns wanted: Get paid to help ensure that every voter has unbiased election information. 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. The Supreme Court's 1962 decision in Baker v. Carr allowed federal courts to hear cases concerning reapportionment and redistricting. Reynolds v. Sims was a case decided by the Supreme Court of the United States in 1964. Just because an issue is deemed to be justiciable in the court of law, does not mean that a case is made moot by the act of voting. 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 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. 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 . States must draw districts based on total population, not voter-eligible population, Justice Ruth Bader Ginsburg wrote on behalf of the majority. They were based on rational state policy that took geography into account, according to the state's attorneys. What amendment did Reynolds v Sims violate? 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. 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. Reynolds v. Sims is a case decided on June 15, 1964, by the United States Supreme Court holding that state legislative districts should be made up of equal populations. 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. Numerous states had to change their system of representation in the state legislature. 320 lessons. 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. The act was temporary and would only be put in place if the first plan was defeated by voters. The existing 1901 apportionment plan violated the Equal Protection Clause of the Fourteenth Amendment. That, coupled with the importance of ensuring all votes are counted equally, makes the issue justiciable. "[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). These three requirements are as follows: 1. 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. In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. The district courts judgement was affirmed, Chief Justice Earl Warren delivered the opinion of the court. He argued that the decision enforced political ideology that was not clearly described anywhere in the U.S. Constitution. 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. [2], Reynolds v. Sims established that the Equal Protection Clause of the Fourteenth Amendment requires both houses of state legislature to be apportioned based on population.[2]. Because this was a requirement of the Equal Protection Clause of the 14. 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. 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 decision for the case of Reynolds v. Sims has special significance because of its relation to the Equal Protection Clause under the 14th Amendment. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . 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. Reynolds v. Sims (1964) - Rose Institute Retrieved from https://www.thoughtco.com/reynolds-v-sims-4777764. 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. v. Abbott, Governor of Texas. ", "Landmark Cases: Reynolds v. Sims (1964)", California Legislative District Maps (1911Present), Lucas v. Forty-Fourth Gen. However, the court found that the issue was justiciable and that the 14th amendment rights of Alabama residents were being violated. Within two years, the boundaries of legislative districts had been redrawn all across the nation. States may have to balance representation based on population with other legislative goals like ensuring minority representation. To determine if an issue is justiciable, the Court will look at the nature of the issue, and if it is one dealing with the political power of either the executive or legislative branches, and if it is unlikely that a ruling by the courts will settle the issue, then is it a political question and is non-justiciable. Whether the issue of the apportionment of Alabama's legislature, having been alleged to violate the 14th Amendment, is a justiciable issue. Reynolds v. Sims: Summary, Decision & Significance
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