Summary
[Reynolds v. Sims 377 U.S. 533 (1964)] was a U.S Supreme Court that decided that Alabama’s legislative apportionment was unconstitutional because it violated the 14th Amendment’s Equal protection clause of the U.S constitution. 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.
Background
The population of Alabama had rapidly grown from 1.8 million citizens to about 3.5 million from 1901 to 1962. Even though most of that growth occurred in urban areas. Alabama’s state’s constitution which was adopted in 1900 specified that state’s legislative districts be apportioned according to population for the basis of representation. It also insisted that this apportionment be conducted every 10 years. Despite the increase in population, the apportionment schemes did not reflect the increase in citizens. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. This inherently nullifies the votes of some citizens and even weighted some more than the other since the distracting scheme did not reflect their population. After the Supreme Court decided in Baker v. Carr (1962) that federal courts have jurisdiction in hearing state’s legislative apportionment cases. The ones that constitutional challenges. Several individuals across 30 states who have being harmed by redistricting and legislative apportionment schemes brought suit in federal courts. Reynolds v. Sims was one that sought to challenge the apportionment schemes of Alabama and came to court seeking a remedy.
Issues
The question in this case was whether Alabama’s legislative apportionment scheme violated the Equal Protection Clause of the 14th Amendment by weighing some votes higher than another?
Decision
The court in an 8-1 decision struck down Alabama’s apportionment scheme as unconstitutional.The court declared in Gary v. Sanders that the aim of “one person, one vote’ should be tried to achieved”. Further stating that the equal protection clause was not designed for representatives whom represent all citizens to be greater or less. The district court’s judgement was affirmed
Majority Opinion
Chief Justice Earl Warren delivered the opinion of the court. The decision held by the court in this case stemmed mainly from a constitutional right to suffrage. 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”. Because this was a requirement of the Equal Protection Clause of the 14th Amendment. As we know that federal law is superior to that of the states. It should also be superior in practice as well. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. It should be noted that Alabama’s legislative apportionment scheme gave more weight to citizens of some areas, mostly rural areas. 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”. It went further to state that “Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests”. This way a way of reiterating the point, since the change in population occurred mainly in urban areas. It concluded by saying both houses of Alabama’s bicameral legislature be apportioned on a population basis. Requiring states to employ honest and good faith practices when creating districts.
Concurring Opinion
Justice Tom Clark wrote a concurring opinion which was joined by no other justice. He stated that the court had gone beyond its own necessity ties in creating and establishing a new ‘equal proportion’ legislative apportionment scheme. He said that the decision evolved from the court’s ruling in Gray v. Sanders that mandated political equality means ‘one person one vote”.
Full Text of Opinions
Concurring Opinion (Justice Stevens)
Concurring Opinion (Justice Clark)
Significance/ Impact
This ruling was so immediately impactful to state legislatures that there was an attempt to pass a constitutional amendment to allow states to have districts of varying populations. In effort to reconcile with the one person one vote principle state governments throughout the nation began to revise their reapportionment criteria. Perhaps most importantly, this case provided the important precedent that courts could intervene in the district schemes of a state if the legislature’s reapportionment was not in line with the Equal Protection clause of the Fourteenth Amendment.
Constitutional Provisions
14th Amendment
Section 1.
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. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
Section 2.
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. 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.
Important Precedents
Baker v. Carr (1962)
Gray v. Sanders (1963)
Wesberry v. Sanders (1964)
Important Subsequent Cases
Gaffney v. Cummnings (1973)
Johnson v. DeGrandy (1994)
Evenwel v. Abbott (2016)
Web Resources
http://caselaw.findlaw.com/us-supreme-court/377/533.html
“Wesberry v. Sanders.” Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22
“Baker v. Carr.” Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1960/6
http://www.pbs.org/wnet/supremecourt/rights/landmark_reynolds.html
http://law2.umkc.edu/faculty/projects/ftrials/conlaw/ReynoldsvSims.html
Contributors
Spring 2016: Mosopefoluwa Ojo,Destiny Williams,Everette Hemphill,Trenton Jackson