Appellant
R. A. Reynolds
Appellee
M. O. Sims
Appellant's Claim
That representation in both houses of state legislatures must be based on population.
Chief Lawyer for Appellant
W. McLean Pitts
Chief Lawyer for Appellee
Charles Morgan, Jr.
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Earl Warren (writing for the Court), Byron R. White
Justices Dissenting
John Marshall Harlan I
Place
Washington, D.C.
Date of Decision
15 June 1964
Decision
The Supreme Court held that the equal representation guarantee of the Fourteenth Amendment requires that the configuration of districts be based on population distribution.
Significance
Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Within two years, the boundaries of legislative districts had been redrawn all across the nation.
The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Baker v. Carr held that federal courts are able to rule on the constitutionality of therelative size of legislative districts. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. The Court's decisionin Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people.
The decision in Wesberry, which concerned federal election districts,was based on Article I of the Constitution, which governs the federal legislative branch. In the landmark case of Reynolds v. Sims, which concernedrepresentation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among theseveral states according to their respective numbers." That is, equal protection under the Fourteenth Amendment--which only applies to the states--guarantees that each citizen shall have equal weight in determining the outcome ofstate elections.
Reynolds was just one of 15 reapportionment cases the Court decided inJune of 1964. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. The Court decidedeach case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims.
Reynolds originated in Alabama, a state which had especially lopsideddistricts and which produced the first judicially mandated redistricting planin the nation. M.O. Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. At thattime the state legislature consisted of a senate with 35 members and a houseof representatives with 106 members. The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas.Since population growth in the state over the next 60 years was uneven, theplaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level.
Shortly after the Supreme Court handed down its decision in Baker v. Carr in March of 1962, under pressure from the federal district court that wasstill considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. These plans were to take effect in time forthe 1966 elections. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. The district court further declared that theredistricting plans recently adopted by the legislature were unconstitutional. After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. The 1962 Alabama general election was conducted on the basisof the court-ordered plan, which was immediately appealed to the U.S. Supreme Court.
"Legislators Represent People, Not Trees"
Chief Justice Warren began his opinion for the Court by noting that because there appeared to be no political remedy to malapportionment in Alabama, the federal courts were obliged to make a ruling. The Equal Protection Clause of the Fourteenth Amendment guarantees that each citizen's vote will have equal weight in determining the outcome of state elections. In order to insure thatthis happened, the federal courts had to devise and enforce redistricting plans that would result in each state representative being elected by and responsive to roughly the same number of voters. As Warren put it:
For the Court, the effect of substantial disparities in population from one district to the next was to deprive some voters of the franchise, while granting others more than one vote.
The Court did recognize some practical limitations on the ideal represented by the principle of "one person, one vote." It was not possible to come up with exact mathematical ratios of how the electorate was to be divided in a given state. And there had to be some acknowledgment of traditional political subdivisions and differing community interests. However, the Court specificallyruled out the use of the federal model in state legislatures. That is, whilein the U.S. Congress the number of representatives is based on state population, regardless of its size each state sends two representatives to the Senate. In Reynolds the Court found that there was convincing evidence thatthree-fourths of the original state constitutions envisioned that the numberof representatives sent to both houses of their state legislatures would be determined by population.
With one stroke, at least one house of most state legislatures was rendered unconstitutional. Over the next two years, the political map of virtually theentire country was redrawn. Yet problems remained. The lone dissenter in Reynolds was Justice Harlan, who argued, as he had in Baker v. Carr, that the Court was interfering with the political process and with the principle of federalism that bound individual states to the union by recognizingtheir autonomy. Indeed, because the Court could arrive at no precise formulafor redistricting, partisan gerrymandering, or manipulation of election boundaries, resulted in more and more litigation. Mathematical models ultimately failed, and new, clearly nonsensical election boundaries began themselves to threaten fair representation.
Justice Harlan declared in his dissent that, "The Constitution is not a panacea for every blot upon the public welfare, nor should this Court, ordained asa judicial body, be thought of as a general haven for reform movements." Butwhere the political process cannot itself cure partisan advantages born of gerrymandering, the Court has continued to intervene, mandating reapportionment to insure fair and effective representation.
Related Cases
The Census
Every ten years since 1790, the United States has conducted a census as authorized by the Constitution. This is far more than a simple headcount; census data provides a detailed national portrait which assists the federal, state, and local governments (and private entities, who also access the information)in demographic-based planning. The Census Bureau distributes detailed questionnaires to households, and the cumulative answers help to determine not onlypopulation, which governs the apportionment of representatives at the state and federal levels, but other trends that will influence policy in areas thatrange from education to the building of interstate highways.
Determining apportionment remains the primary constitutional purpose of the census, and Congress has oversight as to the form and method of the count. Federal marshals were the first census takers, but by 1880 it became necessary for the Census Bureau to hire legions of employees. Since 1970, the census hasbeen by mail. By 1990, critics charged that the mail-based census might notbe effective enough, given the existence of a homeless population largely outside its reach.
Sources
Bacon, Donald C., et al., eds. The Encyclopedia of the United States Congress. New York: Simon & Schuster, 1995.
R. A. Reynolds
Appellee
M. O. Sims
Appellant's Claim
That representation in both houses of state legislatures must be based on population.
Chief Lawyer for Appellant
W. McLean Pitts
Chief Lawyer for Appellee
Charles Morgan, Jr.
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Arthur Goldberg, Potter Stewart, Earl Warren (writing for the Court), Byron R. White
Justices Dissenting
John Marshall Harlan I
Place
Washington, D.C.
Date of Decision
15 June 1964
Decision
The Supreme Court held that the equal representation guarantee of the Fourteenth Amendment requires that the configuration of districts be based on population distribution.
Significance
Reynolds v. Sims rendered at least one house of most legislatures unconstitutional. Within two years, the boundaries of legislative districts had been redrawn all across the nation.
The Supreme Court began what came to be known as the reapportionment revolution with its opinion in the 1962 case, Baker v. Carr. Baker v. Carr held that federal courts are able to rule on the constitutionality of therelative size of legislative districts. The next year, in Gray v. Sanders (1963), the Court declared Georgia's county unit system of electoral districts unconstitutional. Since the Georgia electoral system was based on geography, rather than population, winners of the popular vote often lost elections. Gray v. Sanders gave rise to the phrase "one person, one vote," which became the motto of the reapportionment revolution. The Court's decisionin Wesberry v. Sanders (1964), which invalidated Georgia's unequal congressional districts, articulated the principle of equal representation for equal numbers of people.
The decision in Wesberry, which concerned federal election districts,was based on Article I of the Constitution, which governs the federal legislative branch. In the landmark case of Reynolds v. Sims, which concernedrepresentation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among theseveral states according to their respective numbers." That is, equal protection under the Fourteenth Amendment--which only applies to the states--guarantees that each citizen shall have equal weight in determining the outcome ofstate elections.
Reynolds was just one of 15 reapportionment cases the Court decided inJune of 1964. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. The Court decidedeach case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims.
Reynolds originated in Alabama, a state which had especially lopsideddistricts and which produced the first judicially mandated redistricting planin the nation. M.O. Sims, for whom the case is named, was one of the resident taxpaying voters of Jefferson County, Alabama, who filed suit in federal court in 1961 challenging the apportionment of the Alabama legislature. At thattime the state legislature consisted of a senate with 35 members and a houseof representatives with 106 members. The plaintiffs in the original suit alleged that state legislative districts had not been redrawn since the 1900 federal census, when the majority of the state's residents lived in rural areas.Since population growth in the state over the next 60 years was uneven, theplaintiffs alleged that residents of Jefferson County were seriously underrepresented at the state level.
Shortly after the Supreme Court handed down its decision in Baker v. Carr in March of 1962, under pressure from the federal district court that wasstill considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. These plans were to take effect in time forthe 1966 elections. In July of 1962, the district court declared that the existing representation in the Alabama legislature violated the Fourteenth Amendment's Equal Protection Clause. The district court further declared that theredistricting plans recently adopted by the legislature were unconstitutional. After specifying a temporary reapportionment plan, the district court stated that the 1962 election of state legislators could only be conducted according to its plan. The 1962 Alabama general election was conducted on the basisof the court-ordered plan, which was immediately appealed to the U.S. Supreme Court.
"Legislators Represent People, Not Trees"
Chief Justice Warren began his opinion for the Court by noting that because there appeared to be no political remedy to malapportionment in Alabama, the federal courts were obliged to make a ruling. The Equal Protection Clause of the Fourteenth Amendment guarantees that each citizen's vote will have equal weight in determining the outcome of state elections. In order to insure thatthis happened, the federal courts had to devise and enforce redistricting plans that would result in each state representative being elected by and responsive to roughly the same number of voters. As Warren put it:
Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests. As long as ours is a representative form of government, and our legislatures are those instruments of government elected directly by and directly representative of the people, the rightto elect legislators in a free and unimpaired fashion is a bedrock of our political system.
For the Court, the effect of substantial disparities in population from one district to the next was to deprive some voters of the franchise, while granting others more than one vote.
The Court did recognize some practical limitations on the ideal represented by the principle of "one person, one vote." It was not possible to come up with exact mathematical ratios of how the electorate was to be divided in a given state. And there had to be some acknowledgment of traditional political subdivisions and differing community interests. However, the Court specificallyruled out the use of the federal model in state legislatures. That is, whilein the U.S. Congress the number of representatives is based on state population, regardless of its size each state sends two representatives to the Senate. In Reynolds the Court found that there was convincing evidence thatthree-fourths of the original state constitutions envisioned that the numberof representatives sent to both houses of their state legislatures would be determined by population.
With one stroke, at least one house of most state legislatures was rendered unconstitutional. Over the next two years, the political map of virtually theentire country was redrawn. Yet problems remained. The lone dissenter in Reynolds was Justice Harlan, who argued, as he had in Baker v. Carr, that the Court was interfering with the political process and with the principle of federalism that bound individual states to the union by recognizingtheir autonomy. Indeed, because the Court could arrive at no precise formulafor redistricting, partisan gerrymandering, or manipulation of election boundaries, resulted in more and more litigation. Mathematical models ultimately failed, and new, clearly nonsensical election boundaries began themselves to threaten fair representation.
Justice Harlan declared in his dissent that, "The Constitution is not a panacea for every blot upon the public welfare, nor should this Court, ordained asa judicial body, be thought of as a general haven for reform movements." Butwhere the political process cannot itself cure partisan advantages born of gerrymandering, the Court has continued to intervene, mandating reapportionment to insure fair and effective representation.
Related Cases
- Baker v. Carr, 369 U.S. 186 (1962).
- Gray v. Sanders, 372 U.S. 368 (1963).
- Wesberry v. Sanders, 376 U.S. 1 (1964).
The Census
Every ten years since 1790, the United States has conducted a census as authorized by the Constitution. This is far more than a simple headcount; census data provides a detailed national portrait which assists the federal, state, and local governments (and private entities, who also access the information)in demographic-based planning. The Census Bureau distributes detailed questionnaires to households, and the cumulative answers help to determine not onlypopulation, which governs the apportionment of representatives at the state and federal levels, but other trends that will influence policy in areas thatrange from education to the building of interstate highways.
Determining apportionment remains the primary constitutional purpose of the census, and Congress has oversight as to the form and method of the count. Federal marshals were the first census takers, but by 1880 it became necessary for the Census Bureau to hire legions of employees. Since 1970, the census hasbeen by mail. By 1990, critics charged that the mail-based census might notbe effective enough, given the existence of a homeless population largely outside its reach.
Sources
Bacon, Donald C., et al., eds. The Encyclopedia of the United States Congress. New York: Simon & Schuster, 1995.
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