Reynolds v. Sims
|This article relies largely or entirely upon a single source. (November 2012)|
|Reynolds v. Sims|
|Argued November, 1963
Decided June 15, 1964
|Full case name||Reynolds, Judge, et al. v. Sims, et al.|
|Citations||377 U.S. 533 (more)
84 S. Ct. 1362; 12 L. Ed. 2d 506; 1964 U.S. LEXIS 1002
|Prior history||Appeal from the United States District Court for the Middle District of Alabama|
|The Court struck down state senate inequality, basing their decision on the principle of "one person, one vote."|
|Majority||Warren, joined by Black, Douglas, Brennan, White, Goldberg|
|U.S. Const. amend. XIV, Equal Protection Clause|
Reynolds v. Sims, 377 U.S. 533 (1964) was a United States Supreme Court case that ruled that state legislature districts had to be roughly equal in population. The case was brought on behalf of voters in Alabama, but the decision affected both northern and southern states that had similarly failed to reapportion their legislatures in keeping with changes in state population.
Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, had challenged the apportionment of the Alabama Legislature. The Alabama Constitution provided that there be at least one representative per county and as many senatorial districts as there were senators. 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).
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. Before Reynolds, urban counties were often drastically underrepresented in both northern and southern states.
Among the more extreme pre-Reynolds disparities (compiled by Congressman Morris K. Udall):
- In the Connecticut General Assembly, one House district had 191 people; another, 81,000 (424 times more).
- In the New Hampshire General Court, one township with three people had a Representative in the lower house; this was the same representation given another district with a population of 3,244. The vote of a resident of the first township was therefore 1,081 times more powerful at the Capitol.
- In the Utah State Legislature, the smallest district had 165 people, the largest 32,380 (196 times the population of the other).
- In the Vermont General Assembly, the smallest district had 36 people, the largest 35,000, a ratio of almost 1,000 to 1.
- Los Angeles County, California, then with 6 million people, had one member in the California State Senate, as did the 14,000 people of one rural county (428 times more).
- In the Idaho Legislature, the smallest Senate district had 951 people; the largest, 93,400 (97 times more).
- In the Nevada Senate, 17 members represented as many as 127,000 or as few as 568 people, a ratio of 224 to 1.
The eight justices who struck down state senate inequality based their decision on the principle of "one person, one vote". In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests."
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.
In dissent, Justice John Marshall Harlan II criticized the Court for ignoring the original intent of the Equal Protection Clause, which he argued did not extend to voting rights. Harlan claimed the Court was imposing its own idea of "good government" on the states, stifling creativity and violating federalism. Harlan further claimed that if Reynolds was correct, then the US Constitution's own provision for two senators from each state would be Constitutionally suspect since the fifty states don't have "substantially equal populations". "One person, one vote" was extended to Congressional (but not Senate) districts in Wesberry v. Sanders (1964).
Reynolds v. Sims set off a legislative firestorm in the country. Senator Everett Dirksen of Illinois led a fight to pass a constitutional amendment allowing unequal legislative districts. He warned that
- "...the forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. If they were, the 6 million citizens of the Chicago area would hold sway in the Illinois Legislature without consideration of the problems of their 4 million fellows who are scattered in 100 other counties. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit.."
Numerous states had to change their system of representation in the state legislature. For instance, South Carolina had elected one state senator from each county, resulting in under-representation of urbanized areas. It devised a reapportion scheme and passed an amendment providing for home rule to counties.
- Rotten borough, an English phenomenon
- The Shaff plan
- List of United States Supreme Court cases, volume 377
Works related to Reynolds v. Sims at Wikisource