Reynolds v. Sims

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 the relative 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 decision in 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 concerned representation in state legislatures, the outcome was based on the Fourteenth Amendment requirement that, "Representatives shall be apportioned among the several 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 of state elections.

Reynolds was just one of 15 reapportionment cases the Court decided in June of 1964. All of these cases questioned the constitutionality of state redistricting legislation mandated by Baker v. Carr. The Court decided each case individually, but it announced the controlling philosophy behind the decisions in Reynolds v. Sims.

Reynolds originated in Alabama, a state which had especially lopsided districts and which produced the first judicially mandated redistricting plan in 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 that time the state legislature consisted of a senate with 35 members and a house of 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, the plaintiffs 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 was still considering Sims's case, the Alabama legislature adopted two reapportionment plans, one for each house. These plans were to take effect in time for the 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 the redistricting 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 basis of the court-ordered plan, which was immediately appealed to the U.S. Supreme Court.