Reynolds v. Sims

Supreme Court of United States
377 U.S. 533 (1964)

ELI5:

Rule of Law:

The Equal Protection Clause of the Fourteenth Amendment requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis, ensuring that each citizen's vote carries substantially equal weight.

Facts:

The Alabama Constitution prescribed legislative apportionment based on the 1900 federal census.
For over 60 years, the Alabama Legislature failed to reapportion itself decennially as required by the state constitution, despite significant and uneven population shifts from rural to urban areas.
This inaction resulted in severe malapportionment, where districts with vastly different populations had equal representation.
By 1960, population-variance ratios between the most and least populous districts were as high as 41-to-1 in the state Senate and 16-to-1 in the state House.
As a result, a minority of Alabama's population (approximately 25.1% for the Senate and 25.7% for the House) resided in districts that could elect a majority of the state legislature.
For example, Jefferson County, with over 600,000 people, was allocated only one state senator, the same as Lowndes County, which had a population of only 15,417.
Alabama citizens, including M.O. Sims, had no effective political remedies, such as an initiative or referendum, to compel the legislature to reapportion.

Procedural Posture:

M.O. Sims and other voters from Jefferson County, Alabama, filed a complaint in the U.S. District Court for the Middle District of Alabama against state officials.
The complaint challenged the constitutionality of Alabama's legislative apportionment, which had not been updated since 1901.
A three-judge District Court was convened, which found it had jurisdiction and that the claims were justiciable.
The District Court deferred action to allow the Alabama Legislature an opportunity to enact a new, constitutional apportionment plan.
The legislature met in a special session and proposed two plans: a constitutional amendment (the '67-Senator Amendment') and a standby statute (the 'Crawford-Webb Act').
The District Court found the existing 1901 apportionment and both newly proposed legislative plans to be unconstitutional because they did not apportion either house on a population basis.
The District Court then ordered its own temporary reapportionment plan into effect for the 1962 elections, combining provisions from the two legislative plans it had otherwise rejected.
The defendant state officials (appellants) and two groups of intervenor-plaintiffs (cross-appellants) appealed the District Court's decision to the U.S. Supreme Court.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state's legislative apportionment scheme that results in substantial disparities in the number of people per legislator across different districts, thereby debasing the weight of votes in more populous districts, violate the Equal Protection Clause of the Fourteenth Amendment?

Opinions:

Majority - Chief Justice Warren

Yes. A state's legislative apportionment scheme resulting in substantial population disparities violates the Equal Protection Clause. The Clause guarantees the opportunity for equal participation by all voters in the election of state legislators, and its core principle is that the weight of a citizen's vote cannot be made to depend on where they live. Legislators represent people, not geographic areas, so both houses of a state legislature must be apportioned substantially on population. The so-called 'federal analogy'—where U.S. Senate representation is based on states, not population—is inapplicable to state legislative bodies, as counties are not sovereign entities like states. Diluting the weight of votes because of place of residence impairs basic constitutional rights just as much as invidious discriminations based on race or economic status.

Dissenting - Justice Harlan

No. State legislative apportionments are wholly free of federal constitutional limitations under the Fourteenth Amendment. The Court's holding is an exercise of amending power, not constitutional interpretation. The history and language of the Fourteenth Amendment, particularly Section 2 which provides a specific remedy for the abridgment of voting rights, demonstrate that its framers deliberately chose not to interfere with the states' plenary power to set apportionment and suffrage requirements. The Court's decision disregards this history and intrudes upon the political domain of state governments, forcing the federal judiciary into a role for which it is ill-suited and creating an inappropriate interference with the independent legislatures of the states.

Concurring - Justice Clark

Yes. The Alabama apportionment schemes were unconstitutional, but the Court's new 'equal population' principle goes beyond what is necessary to decide the case. The existing Alabama plan was a 'crazy quilt' that clearly revealed invidious discrimination and therefore violated the Equal Protection Clause. It is not necessary to hold that both houses must be strictly apportioned by population. If one house meets a population standard, the other could rationally depart from it to account for other factors and represent various elements of the state.

Concurring - Justice Stewart

Yes. The judgment should be affirmed because Alabama's 1901 apportionment scheme became unconstitutional due to legislative inaction for over 60 years in the face of major population shifts. This inaction converted the plan into one 'completely lacking in rationality,' which violates the Equal Protection Clause. The District Court acted properly in framing a remedy that adhered as closely as possible to plans approved by Alabama's representatives while giving the state an opportunity to devise its own constitutional system.

Analysis:

Reynolds v. Sims is a landmark decision that established the 'one person, one vote' principle for state legislative apportionment. This ruling fundamentally reshaped American politics by shifting legislative power from historically overrepresented rural areas to rapidly growing urban and suburban centers. By rejecting non-population factors like history or geography as primary justifications for apportionment, the Court cemented population equality as the bedrock standard under the Equal Protection Clause. The decision expanded federal judicial power into the 'political thicket' of state districting, leading to decades of litigation and requiring nearly every state to redraw its legislative maps to comply with the new constitutional mandate.

Gunnerbot

AI-powered case assistant

Loaded: Reynolds v. Sims (1964)

Try: "What was the holding?" or "Explain the dissent"