'And still again, after the adoption of the fourteenth amendment, it was deemed necessary to adopt . Redressability, where the individual suffering from the injury can be aided by some type of compensation dependent on a ruling by the court. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. Star Athletica, L.L.C. Some states refused to engage in regular redistricting, while others enshrined county by county representation (Like the federal government does with state by state representation) in their constitutions. Let's say your county sent five representatives to the state legislature, just like your neighboring county. The political question doctrine asserts that a case can be remedied by the courts if the case is not of strictly political nature. Create an account to start this course today. To unlock this lesson you must be a Study.com Member. Harlan contended that the Supreme Court did not have the authority to interfere in local matters. In the case, plaintiffs in Jefferson County, Alabama sued the state in 1961, alleging that Alabama's continued use of . 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. By the 1960s, the 1901 plan had become "invidiously discriminatory," the attorneys alleged in their brief. Denise DeCooman was a teaching assistant for the General Zoology course at California University of Pennsylvania while she earned her Master's of Science in Clinical Mental Health Counseling from fall semester of 2015 and spring of 2017. TLDR: "That's just your opinion, man Earl." Sims and Baker v.Carr said that state governments couldn't simply iterate the form of the federal government (one chamber apportioned by population, one chamber apportioned by existing political divisions), that state legislatures and every lower level had to be one-person-one-vote-uber-alles.As Justice Frankfurter pointed out in dissent in Baker . It must be likely, rather than speculative, that a favorable decision by the court will redress the injury. [] Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society. We are advised that States can rationally consider . Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor. The decision of this case led to the adoption of the one person, one vote principle, which is a rule that is applied to make sure that legislative districts are zoned so that they are closer to equal in population, in accordance with when the census is taken every ten years. Significance Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. If the case of Alabama's legislative districts needing proper apportionment was considered a justiciable cause. Amendment by weighing some votes higher than another? The ruling in Reynolds v. Sims led to the one person, one vote rule, which aids in making sure legislative districts are divided equally so individual voting rights are not violated. ThoughtCo. They alleged that the legislature had not reapportioned house and senate seats since 1901, despite a large increase in Alabama's population. Click here to contact us for media inquiries, and please donate here to support our continued expansion. In another case, Wesberry v. Sanders, the Court applied the one person, one vote principle to federal districts for electing members of the House of Representatives. The Supreme Court affirmed the decision of the United States District Court for the Middle District of Alabama.[1][2][3]. Mullane v. Central Hanover Bank & Trust Co. Cleveland Board of Education v. Loudermill, Cruzan v. Director, Missouri Department of Health, Cumming v. Richmond County Board of Education, Sipuel v. Board of Regents of the University of Oklahoma, Davis v. County School Board of Prince Edward County, Griffin v. County School Board of Prince Edward County, Green v. County School Board of New Kent County, United States v. Montgomery County Board of Education, Alexander v. Holmes County Board of Education, Swann v. Charlotte-Mecklenburg Board of Education. Unfortunately, in June 2013 the Supreme Court repealed several important aspects of the . It called for a 106-member House and a 35-member Senate. Baker v. It established the precedent that felons are not allowed to vote.B.) It remanded numerous other apportionment cases to lower courts for reconsideration in light of the Baker and Reynolds decisions. Legislative districts in Alabama still reflected the population of 1900 and no reapportionment had being conducted since. REYNOLDS V. SIMSReynolds v. Sims is a landmark case, 377 U.S. 533, 84 S. Ct. 1362, 12 L. Ed. Learn about the Supreme Court case, Reynolds v. Sims. 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. Attorneys representing the voters argued that Alabama had violated a fundamental principle when it failed to reapportion its house and senate for close to 60 years. if(document.getElementsByClassName("reference").length==0) if(document.getElementById('Footnotes')!==null) document.getElementById('Footnotes').parentNode.style.display = 'none'; Communications: Alison Graves Carley Allensworth Abigail Campbell Sarah Groat Caitlin Vanden Boom Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. On this Wikipedia the language links are at the top of the page across from the article title. Chicago-Kent College of Law at Illinois Tech, n.d. May 2, 2016. https://www.oyez.org/cases/1963/22, Baker v. Carr. Oyez. 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. Reynolds, and the citizens who banded together with him, believed that the lack of update in the apportioned representatives violated the Alabama state constitution since representatives were supposed to be updated every ten years when a census was completed. Reynolds and a group of other citizens from Jefferson County, Alabama, presented their case that the state constitution of Alabama was not being followed. Box v. Planned Parenthood of Indiana and Kentucky, Inc. Monell v. Department of Social Services of the City of New York, Will v. Michigan Department of State Police, Inyo County v. Paiute-Shoshone Indians of the Bishop Community, Fitzgerald v. Barnstable School Committee. 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. Reynolds contended that the districts needed to be redrawn since they had remained the same since 1901. Yes. 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 Fourteenth Amendment does not allow this Court to impose the equal population rule in State elections. The Supreme Court came about an 8-to-1 vote in favor of Reynolds, which Chief Justice Earl Warren stated in the majority opinion. Create your account. Reynolds, along with several other people who were all residents, taxpayers and voters from Jefferson County in Alabama, filed a suit in Federal District Court challenging the apportionment of the Alabama state legislature. copyright 2003-2023 Study.com. In Reynolds v. Sims, the court stated that state legislature districts had to be approximately equal in terms of population. The ones that constitutional challenges. All rights reserved. v. Abbott, Governor of Texas. 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. Even though most of that growth occurred in urban areas. The case of Reynolds v. Sims was initially argued November 13, 1963, but a decision on this case was not reached until June 15, 1964. A likely (not speculative) injury was suffered by an individual, 2. 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 unequal populations among the states. Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, League of United Latin American Citizens v. Perry, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. Interns wanted: Get paid to help ensure that every voter has unbiased election information. This means that individuals are guaranteed the same rights and liberties, regardless of minor or irrelevant differences between them. Chief Justice Earl Warren delivered the opinion of the court. 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. Chief Lawyer for Appellant W. McLean Pitts Chief Lawyer for Appellee Charles Morgan, Jr. 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. Create your account. To read more about the impact of Reynolds v. Sims click here. [6], Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. As mentioned earlier in this lesson, the one person, one vote clause is applicable to the Equal Protection Clause because it was ruled that voting is a protected right of the citizens of Alabama, and all other states. The Equal Protection Clause requires a States legislature to represent all citizens as equally as possible. Voters in several Alabama counties sought a declaration that the States legislature did not provide equal representation of all Alabama citizens. Further, the District Courts remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment. The Equal Protection Clause is a portion of the 14th Amendment that posits that Americans should be governed equally, and with impartiality. The Alabama Constitution provided that there be only one state senator per county. Justice Tom Clark wrote a concurring opinion which was joined by no other justice. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. Chappelle v. Greater Baton Rouge Airport Dist. The District Courts remedy of temporary reapportionment was appropriate for purposes of the 1962 elections, and it allows for the reapportioned legislature a chance to find a permanent solution for Alabama. Yet Another Question demonstrating how people so fundamentally misunderstand the United States. There are three basic requirements for one to have legal standing in a court case when attempting to file a lawsuit, according to the laws governing the United States of America. Reynolds and other voters in Jefferson County, Alabama, challenged the state's legislative apportionment for representatives. - Definition, Uses & Effects, Class-Based System: Definition & Explanation, What is a First World Country? 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. The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Spitzer, Elianna. 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. A case that resulted in a one person, one vote ruling and upheld the 14th Amendments equal protection clause. This was not an easy ruling - the Court was deeply divided over the issue, and the sentiment was strong for the federal courts to stay out of the state matter. At the end of July 1962, the district court reached a ruling. Reynolds was a resident of Jefferson County, Alabama. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. The Fourteenth Amendment guarantees equal protection under the law. Perhaps most importantly, this case provided the important precedent that courts could intervene in the district schemes of a state if the legislatures reapportionment was not in line with the Equal Protection clause of the Fourteenth Amendment. State created legislative districts should not in any way jeopardize a right that is prescribed in the constitution. It concluded by saying both houses of Alabamas bicameral legislature be apportioned on a population basis. U.S. Supreme Court Cases: Study Guide & Review, Malloy v. Hogan: Summary, Decision & Significance, Psychological Research & Experimental Design, All Teacher Certification Test Prep Courses, Decision of One Person, One Vote Court Case, Griffin v. County School Board of Prince Edward County, Reynolds v. Sims: Summary, Decision & Significance, Jacobellis v. Ohio: Case, Summary & Facts, McLaughlin v. Florida: Summary, Facts & Decision, Heart of Atlanta Motel, Inc. v. United States (1964), Katzenbach v. McClung: Summary, Decision & Significance, United States v. Seeger: Case, Summary & Decision, Griffin v. California: Summary & Decision, ILTS School Counselor (235): Test Practice and Study Guide, GED Social Studies: Civics & Government, US History, Economics, Geography & World, Introduction to Human Geography: Help and Review, Foundations of Education: Certificate Program, NY Regents Exam - Global History and Geography: Help and Review, NY Regents Exam - Global History and Geography: Tutoring Solution, DSST Foundations of Education: Study Guide & Test Prep, Praxis Core Academic Skills for Educators: Reading (5713) Prep, Praxis Core Academic Skills for Educators - Writing (5723): Study Guide & Practice, What is a Magnetic Compass?