Reynolds v. Sims
|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|
This case overturned a previous ruling or rulings
|Colegrove v. Green, 328 U.S. 549 (1946)|
Reynolds v. Sims, 377 U.S. 533 (1964) was a United States Supreme Court case that ruled that unlike in the election of the United States Senate, in the election of any chamber of a state legislature the electoral districts must be roughly equal in population (thus negating the traditional function of a State Senate, which was to allow rural counties to counterbalance large towns and cities). The case was brought on behalf of voters in Alabama by M.O. Sims, a taxpayer in Birmingham, Alabama, but affected both northern and southern states that had similarly failed to reapportion their legislatures in keeping with changes in state population after its application in five companion cases in Colorado, New York, Maryland, Virginia, and Delaware.
That a State Senate was to represent rural counties, as a counterbalance to towns and cities, was understood before industrialization and urbanization of the United States. State and national legislatures had been reluctant to redistrict. This reluctance developed 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 that would severely inhibit the power of business interests who controlled state and city governments early in the century. Of the forty-eight states then in the Union, only seven[a] twice redistricted even one chamber of their legislature following both the 1930 and the 1940 Censuses. Oregon did not redistrict between 1907 and 1960, Illinois not between 1910 and 1955, while Alabama and Tennessee had at the time of Reynolds not redistricted since 1901. In Connecticut, Vermont, Mississippi and Delaware, apportionment was fixed by the states’ constitutions, which when written in the late eighteenth or nineteenth centuries could not have imagined the possibility of rural depopulation as was to occur during the first half of the century.
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 nationwide often had total representations similar to rural counties, and in Florida, there was a limit to three representatives even for the most populous counties.
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 only one state senator per county. 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).
- In the Connecticut General Assembly, one House district had 191 people.
- 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.
- In the Utah State Legislature, the smallest district had 165 people, the largest 32,380.
- In the Vermont General Assembly, the smallest district had 36 people, the largest 35,000.
- Los Angeles County, California, then with six million people, had one member in the California State Senate, as did the 14,000 people of one rural county.
- In the Idaho Senate, the smallest district had 951 people; the largest, 93,400.
- In the Nevada Senate, seventeen members represented as many as 127,000 or as few as 568 people.
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.” 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 un-equal populations among the states.
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 wrote that the majority had chosen to ignore the language, history, and original intent of the Equal Protection Clause, which did not extend to voting rights. The dissent strongly accused the Court of repeatedly amending the Constitution through its opinions, rather than waiting for the lawful amendment process: "the Court's action now bringing them (state legislative apportionments) within the purview of the Fourteenth Amendment amounts to nothing less than an exercise of the amending power by this Court." Interestingly, the Court soon extended “one person, one vote” to all U.S. congressional districts in Wesberry v. Sanders (1964), but not to the senate.
Since the ruling applied different representation rules to the states than was applicable to the federal government, Reynolds v. Sims set off a legislative firestorm across the country. 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. 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. 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. It devised a reapportionment plan and passed an amendment providing for home rule to counties. However, as all states affected retained their state senates and state senators being elected from Single-member districts, rather than abolishing the upper houses, as was done in Nebraska and Canada, or switched to electing state senators by proportional representation from several large multi-member districts or from one statewide at-large district, as was done in Australia, allegations of State Senates being redundant bodies arose post Reynolds v. Sims.
- Rotten borough, an English phenomenon
- The Shaff Plan
- Alabama Legislative Black Caucus v. Alabama
- List of United States Supreme Court cases, volume 377
- Sullivan, Kathleen M.; Feldman, Noah (2013). Constitutional Law (18th ed.). St. Paul, MN: Thomson Reuters/Foundation Press. p. 779. ISBN 978-1-60930-251-1.
- Smith, J. Douglas (2015). On Democracy’s Doorstep: The Inside Story of How the Supreme Court Brought “One Person, One Vote” to the United States. Hill & Wang. pp. 4–18. ISBN 978-0-8090-7424-2.
- Rodden, Jonathan A. (March 25, 2011). The Long Shadow of the Industrial Revolution: Political Geography and the Representation of the Left (PDF). Stanford University. Retrieved January 3, 2018.
- Baker, Gordon E. (1979). Rural Versus Urban Political Power: The Nature and Consequences of Unbalanced Representation. Praeger. p. 4. ISBN 978-0-313-21223-9.
- Shull, Charles W.; ‘Reapportionment: A Chronic Problem’; National Municipal Review; 30 (1941); pp. 73-79
- Harvey; Lashey G.; ‘Reapportionments of State Legislatures: Legal Requirement’; Law and Contemporary Problems, April 1, 1952, Vol.17(2), pp.364-376
- Baker; Rural Versus Urban Political Power; p. 14
- Udall, Morris K. (October 14, 1964). "Reapportionment--I "One Man, One Vote" . . . That's All She Wrote!". Congressman's Report. University of Arizona. Retrieved January 3, 2018.
- McBride, Alex (December 2006). "Landmark Cases: Reynolds v. Sims (1964)". The Supreme Court. WNET. Retrieved January 3, 2018.
- "CALIFORNIA: Do we need state senators?". The Press-Enterprise. December 17, 2011. Retrieved January 3, 2018.
Works related to Reynolds v. Sims at Wikisource