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Reynolds v. Sims
 | |
| Reynolds v. Sims | |
| Reference: 377 U.S. 533 | |
| Term: 1964 | |
| Important Dates | |
| Argued: November 13, 1963 Decided: June 15, 1964 | |
| Outcome | |
| United States District Court for the Middle District of Alabama affirmed | |
| Majority | |
| Earl Warren • Hugo Black • William Douglas • William Brennan • Byron White • Arthur Goldberg | |
| Concurring | |
| Tom Clark • Potter Stewart | |
| Dissenting | |
| John Harlan II | |
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 case concerned whether the apportionment of Alabama's state legislature violated the Equal Protection Clause of the Fourteenth Amendment of 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]
Why it matters: The Supreme Court's decision in this case established that state legislative districts should be made up of equal populations. To read more about the impact of Reynolds v. Sims click here.
Background
- See also: Redistricting in Alabama
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). 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. 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. The constitution also provided for reapportionment to take place following each decennial census.[4][5]
Case history
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 plaintiffs alleged that reapportionment had not occurred in Alabama since the adoption of the 1901 Alabama Constitution. 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). 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."[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). 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 Crawford-Webb Act provided 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 35-member state senate (with districts drawn to adhere to existing county lines).[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 district court also ruled that the proposed constitutional amendment and the Crawford-Webb Act were insufficient remedies to the constitutional violation. The district court ordered Alabama election officials to conduct the 1962 elections using a temporary apportionment plan devised by the court. The district court ruling was appealed to the Supreme Court of the United States, with the following question being considered:[6][4][5]
| “ | Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances?[7] | ” |
Oral argument
Oral argument was held on November 13, 1963. The case was decided on June 15, 1964.[1]
Decision
The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Middle District of Alabama. Chief Justice Earl Warren delivered the opinion of the court. Justice John Harlan II wrote a dissenting opinion.[2]
Opinions
Opinion of the court
Chief Justice Earl Warren, writing for the court, argued that Alabama's apportionment system violated the Equal Protection Clause of the Fourteenth Amendment. Warren contended that state legislatures must be apportioned by population to provide citizens with direct representation.[2]
| “ | 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. Simply stated, an individual's right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State. 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. 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.[7] | ” |
| —Earl Warren, majority opinion in Reynolds v. Sims[2] | ||
Dissenting opinion
Justice John Harlan II, in a dissenting opinion, argued that the Equal Protection Clause did not apply to voting rights. Harlan contended that the Supreme Court did not have the authority to interfere in local matters.[2]
| “ | 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. Whatever may be thought of this holding as a piece of political ideology -- and even on that score, the political history and practices of this country from its earliest beginnings leave wide room for debate -- I think it demonstrable that the Fourteenth Amendment does not impose this political tenet on the States or authorize this Court to do so.[7] | ” |
| —John Harlan II, dissenting opinion in Reynolds v. Sims[2] | ||
Impact
| Federalism |
|---|
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Gerrymandering
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]
See also
- The Warren Court
- Supreme Court of the United States
- History of the Supreme Court
- Federalism
- Redistricting in Alabama
- Wesberry v. Sanders
- Gerrymandering
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 Oyez, "Reynolds v. Sims," accessed August 8, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 Justia, "Reynolds v. Sims, 377 U.S. 533 (1964)," accessed August 8, 2022
- ↑ LexisNexis, "Reynolds v. Sims - 377 U.S. 533, 84 S. Ct. 1362 (1964)," accessed August 8, 2022
- ↑ 4.0 4.1 4.2 4.3 Supreme Court of the United States, "Reynolds v. Sims: Opinion," June 15, 1964
- ↑ 5.0 5.1 5.2 5.3 Encyclopedia of Alabama, "Reynolds v. Sims," accessed December 11, 2017
- ↑ Oyez, "Reynolds v. Sims," accessed December 11, 2017
- ↑ 7.0 7.1 7.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
