Reynolds v. Sims

Reynolds v. Sims, 377 U.S. 533 (1964), was a landmark United States Supreme Court case in which the Court ruled that the electoral districts of state legislative chambers must be roughly equal in population. Along with Baker v. Carr (1962) and Wesberry v. Sanders (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies.

Reynolds v. Sims
Supreme Court of the United States
Argued November, 1963
Decided June 15, 1964
Full case nameReynolds, Judge, et al. v. Sims, et al.
Citations377 U.S. 533 (more)
84 S. Ct. 1362; 12 L. Ed. 2d 506; 1964 U.S. LEXIS 1002
ArgumentOral argument
Case history
PriorAppeal 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
Chief Justice
Earl Warren
Associate Justices
Hugo Black · William O. Douglas
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Potter Stewart
Byron White · Arthur Goldberg
Case opinions
MajorityWarren, joined by Black, Douglas, Brennan, White, Goldberg
ConcurrenceClark
ConcurrenceStewart
DissentHarlan
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)
Wikisource has original text related to this article:

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 the industrialization and urbanization of the United States, a State Senate was understood to represent rural counties, in most states as a counterbalance to towns and cities. Of the forty-eight states then in the Union, only seven[lower-alpha 1] twice redistricted even one chamber of their legislature following both the 1930 and the 1940 Censuses.[2][3] Illinois did not redistrict between 1910 and 1955,[4] 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, did not foresee the possibility of rural depopulation as was to occur during the first half of the century.[2] In New Hampshire the state constitutions, since January 1776, had always called for the state senate to be apportioned based on taxes paid, rather than on population.

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.[3]

The case
See also: Alabama Constitution of 1901 § Notable features

Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, 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). The case was named for M. O. Sims, one of the voters who brought the suit, and B. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit.[5] Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.[6]

Among the more extreme pre-Reynolds disparities[7] claimed by Morris K. Udall:

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 "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 unequal populations among the states.

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 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, allegations of State Senates being redundant arose, as all states affected retained their state senates, with state senators being elected from single-member districts, rather than abolishing the upper houses, as had been done in 1936 in Nebraska[lower-alpha 2] (and in the provinces of Canada), or switching 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.[12]

Reactions

In a 2015 Time Magazine survey of over 50 law professors, both Erwin Chemerinsky (Dean, UC Berkeley School of Law) and Richard Pildes (NYU School of Law) named Reynolds v. Sims the "best Supreme Court decision since 1960", with Chemerinsky noting that in his opinion, the decision made American government "far more democratic and representative."[1]

See also

References
  1. 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.
  2. Shull, Charles W. (1941). "Reapportionment: A Chronic Problem". National Municipal Review. 30 (2): 73–79. doi:10.1002/ncr.4110300204.
  3. Harvey, Lashey G. (1952). "Reapportionments of State Legislatures: Legal Requirement". Law and Contemporary Problems. 17 (2): 364–376. doi:10.2307/1190238. JSTOR 1190238.
  4. Baker; Rural Versus Urban Political Power; p. 14
  5. Brown, Steven P. "Reynolds v. Sims". Encyclopedia of Alabama. Retrieved December 21, 2022.
  6. "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.
  7. 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.
  8. "New Hampshire 1960-2010 Town and County populations". New Hampshire Office of Strategic Initiatives. Retrieved March 5, 2023.
  9. Manual for the General Court, 1961. Concord, N.H. : Dept. of State. January 1, 1961. pp. 233–241. Retrieved March 5, 2023.
  10. "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.
  11. McBride, Alex (December 2006). "Landmark Cases: Reynolds v. Sims (1964)". The Supreme Court. WNET. Retrieved January 3, 2018.
  12. "CALIFORNIA: Do we need state senators?". The Press-Enterprise. December 17, 2011. Retrieved January 3, 2018.

Notes
  1. These being New Jersey, Massachusetts, New Hampshire (lower house only), Maine, South Dakota, Montana and Nevada (lower house only)
  2. 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.
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