Reynolds v. Sims
Following is the case brief for Reynolds v. Sims, 377 U.S. 533 (1964)
Case Summary of Reynolds v. Sims:
- Voters in several Alabama counties sought a declaration that the State’s legislature did not provide equal representation of all Alabama citizens.
- The federal district court, unsatisfied with Alabama’s proposals to remedy the representation problem, ordered temporary reapportionment for the 1962 general election.
- State officials appealed, arguing that the existing and proposed reapportionment plans are constitutional, and that the district court lacked the power to order temporary reapportionment.
- The U.S. Supreme Court affirmed the district court, holding that the Equal Protection Clause requires that both houses of a state legislature must be apportioned on a population basis.
Reynolds v. Sims Case Brief
Statement of the Facts:
Several groups of voters, in separate lawsuits, challenged the constitutionality of the apportionment of the Alabama Legislature. The 1901 Alabama Constitution provided for representation by population in both houses of the State Legislature. After 60 years of significant population growth, some areas of the State had grown in population far more than others.
Because the number of representatives for each district remained the same over those 60 years, some voters in the State had a greater voice in government than others. The voters claimed that the unfair apportionment deprived many voters of equal protection under the Fourteenth Amendment and the Alabama Constitution.
Procedural History:
- The District Court for the Middle District of Alabama found that the reapportionment plans proposed by the Alabama Legislature would not cure the inequality in representation, and it ordered a temporary reapportionment for the 1962 general election.
- State officials appealed, arguing that Alabama’s existing and proposed reapportionment plans are constitutional and that the District Court lacked the power to reapportion the Legislature itself.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Does the Equal Protection Clause require a State to have substantially equal representation by population in both houses of a bicameral legislature? Yes.
Judgment:
The decision of the District Court for the Middle District of Alabama is affirmed, and remanded.
Rule of Law or Legal Principle Applied:
The Equal Protection Clause of the Fourteenth Amendment requires that representatives in both houses of a State’s bicameral legislature must be apportioned by population.
Reasoning:
Dilution of a person’s vote infringes on his or her right of suffrage. The Equal Protection Clause requires a State’s legislature to represent all citizens as equally as possible. State representatives represent people, not geographic regions. Therefore, having some votes weigh less than others just because of where a person lives violates equal protection of the laws.
Accordingly, the Equal Protection Clause demands that both houses in a State’s bicameral legislature must be apportioned on a population basis. The District Court was correct to come to that holding and to reject the State’s proposed apportionment plans.
Simply because one of Alabama’s apportionment plans resembled the Federal set up of a House comprised of representatives based on population, and a Senate comprised of an equal number of representatives from each State does not mean that such a system is appropriate in a State legislature. The reason for a non-population-based Federal Senate has more to do with a compromise that allowed for the creation of a national government. Any one State does not have such issues. Therefore, requiring both houses of a State bicameral legislature to apportion on a population basis is appropriate under the Equal Protection Clause.
The District Court’s 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.
Concurring and Dissenting Opinions:
Concurring in the Judgment (Clark):
The Court goes beyond what this case requires by enforcing some form of “one person, one vote” principle. All the Court need do here is note that the plans at play reveal invidious discrimination that violates equal protection.
Concurring Opinion (Stewart):
It is clear that 60 years of inaction on the Alabama Legislature’s part has led to an irrational legislative apportionment plan. Further, the District Court’s remedy was appropriate because it gave the State an opportunity to fix its own system of apportionment.
Dissenting Opinion (Harlan):
The Fourteenth Amendment does not allow this Court to impose the “equal population” rule in State elections. The history of the Equal Protection Clause has nothing to do with a State’s choice in how to apportion their legislatures.
Significance:
Reynolds v. Sims is famous for, and has enshrined, the “one person, one vote” principle. In this case, the context was with regard to State legislatures. 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.
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