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 single-seat 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.

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**Reynolds v. Sims **

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 ; although the Constitution of Alabama provided for both houses to be apportioned on the basis of population (a requirement that could not be changed by constitutional amendment ), the Alabama Legislature failed to conduct the required periodic redistricting and even proposed a constitutional amendment which – in violation of the constitution's eternity clause – would provide 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 a concurring opinion, Associate Justice Tom Campbell Clark allowed one house to deviate from this standard only as long as the other house complies with it, while 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.

Contents

• 1 Historical background

• 2 Procedural history

• 3 Decision

• 4 Aftermath

  • 4.1 Reactions

• 5 See also

• 6 References

• 7 Notes

• 8 External links

Historical background

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Before the industrialization and urbanization of the United States, a state senate in most states was understood to represent rural counties as a counterbalance to towns and cities. Of the forty-eight states then in the Union, only seven twice redistricted even one chamber of their legislature following both the 1930 and the 1940 Censuses .

Illinois did not redistrict 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, did not foresee the possibility of rural depopulation as was to occur during the first half of the century.

Among the more extreme pre-Reynolds disparities 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.

• 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.

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.

Procedural history

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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 paradoxically provided that, although senatorial districts have to have as equal a population as possible, counties cannot be split across several senatorial districts. 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. Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama.

Decision

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The right to vote freely for the candidate of one's choice is of the essence of a democ

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