Reynolds v. Sims
Reynolds v. Sims | |
---|---|
Argument | Oral argument |
Case history | |
Prior | Appeal from the United States District Court for the Middle District of Alabama |
Holding | |
State senate districts must have roughly equal populations based on the principle of "one person, one vote". | |
Court membership | |
| |
Case opinions | |
Majority | Warren, joined by Black, Douglas, Brennan, White, Goldberg |
Concurrence | Clark |
Concurrence | Stewart |
Dissent | Harlan |
Laws applied | |
U.S. Const. amend. XIV (Equal Protection Clause) | |
This case overturned a previous ruling or rulings | |
Colegrove v. Green, 328 U.S. 549 (1946) (in part) |
Reynolds v. Sims, 377 U.S. 533 (1964), was a
Prior to the case, numerous state legislative chambers had districts containing unequal populations; for example, in the Nevada Senate, the smallest district had 568 people, while the largest had approximately 127,000 people. Some states refused to engage in regular redistricting, while others enshrined county by county representation (like the U.S. constitution does with state by state representation) in their constitutions. The case of Reynolds v. Sims arose after voters in Birmingham, Alabama, challenged the apportionment of the Alabama Legislature; the Constitution of Alabama provided for one state senator per county regardless of population differences.
In a majority opinion joined by five other justices, Chief Justice Earl Warren ruled that the Fourteenth Amendment's Equal Protection Clause requires states to establish state legislative electoral districts roughly equal in population. Warren held that "legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests." In his dissenting opinion, Associate Justice John Marshall Harlan II argued that the Equal Protection Clause was not designed to apply to voting rights. The decision had a major impact on state legislatures, as many states had to change their system of representation.[1]
Historical background
Before
Having already overturned its ruling that redistricting was a purely political question in
The case
Voters from
Among the more extreme pre-Reynolds disparities[7] claimed by Morris K. Udall:
- In the Connecticut General Assembly, one House district had 191 people.
- In the New Hampshire General Court, the Town of Ellsworth with a population of three people had a Representative in the lower house; this was the same representation given to Bedford, with a population of 3,636.[8][9]
- 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.
- In the Idaho Senate, the smallest district had 969 people; the largest, 93,400.
- In the Nevada Senate, seventeen members represented as many as 127,000 or as few as 568 people.
Decision
The right to vote freely for the candidate of one's choice is of the essence of a democratic society, and any restrictions on that right strike at the heart of representative government. And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen's vote just as effectively as by wholly prohibiting the free exercise of the franchise. [...] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and political rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized.
--Chief Justice Earl Warren on the right to vote as the foundation of democracy in Reynolds v. Sims (1964).[10]
The eight justices who struck down state senate inequality based their decision on the principle of "
Justice Tom C. Clark wrote a concurring opinion. 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." The Court had already extended "one person, one vote" to all U.S. congressional districts in Wesberry v. Sanders (1964) a month before, but not to the Senate.
Aftermath
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.[11] 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
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,
Reactions
In a 2015
See also
- The Shaff Plan
- Alabama Legislative Black Caucus v. Alabama, 575 U.S. ___ (2015)
- List of United States Supreme Court cases, volume 377
References
- ^ a b Sachs, Andrea (October 6, 2015). "The Best Supreme Court Decisions Since 1960". Time. Retrieved October 1, 2018.
Among the decisions repeatedly praised by the law-school professors were those that championed civil and individual liberties, as well as those that made democracy more participatory. Decisions that were often mentioned included Loving v. Virginia (1967), which found restrictions on interracial marriage unconstitutional; New York Times Co. v. Sullivan (1964), which protected freedom of the press in the realm of political reporting and libel; Baker v. Carr (1962) and Reynolds v. Sims (1964), which established the one-person, one-vote concept in legislative apportionment; and Obergefell v. Hodges, the 2015 same-sex-marriage ruling.
- ^ .
- ^ JSTOR 1190238.
- ^ Baker; Rural Versus Urban Political Power; p. 14
- ^ Brown, Steven P. "Reynolds v. Sims". Encyclopedia of Alabama. Retrieved December 21, 2022.
- ^ "B. A. REYNOLDS, etc., et al., Appellants, v. M. O. SIMS et al. David J. VANN and Robert S. Vance, Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al. John W. McCONNELL, Jr., et al., Appellants, v. Agnes BAGGETT, Secretary of State of Alabama et al". LII / Legal Information Institute. Cornell University. Retrieved December 21, 2022.
- ^ Udall, Morris K. (October 14, 1964). "Reapportionment--I "One Man, One Vote"... That's All She Wrote!". Congressman's Report. University of Arizona. Archived from the original on October 10, 2017. Retrieved January 3, 2018.
- ^ "New Hampshire 1960-2010 Town and County populations". New Hampshire Office of Strategic Initiatives. Retrieved March 5, 2023.
- ^ Manual for the General Court, 1961. Concord, N.H. : Dept. of State. January 1, 1961. pp. 233–241. Retrieved March 5, 2023.
- ^ "Reynolds v. Sims, 377 U.S. 533 (1964), at 555 and 561-562". Justia US Supreme Court Center. June 15, 1964. Retrieved January 5, 2021.
- ^ 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.
Notes
- lower houseonly)
- ^ Technically, Nebraska abolished the lower house of its legislature, granting its powers to the Nebraska Senate (which was renamed simply the "Nebraska Legislature"), but the end result was effectively the same.
External links
- Text of Reynolds v. Sims, 377 U.S. 533 (1964) is available from: Findlaw Justia Library of Congress
- California Legislative District Maps (1911–Present)