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Reynolds v. Sims, 377 U.S. 533 |
Supreme Court of the United States |
1964 |
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Chapter |
6 |
Title |
Implied Fundamental Rights |
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Page |
775 |
Topic |
District reapportionment impair vote weight, where the minority controls the Legislature |
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Quick Notes |
The Alabama Legislature had not reapportioned the district in 60 years. The scheme enabling a minority of voters to control the State Legislature. The voting scheme did not change over time to reflect the increase of population in the districts.
Rule o A State must structure its elections and its state legislature so that its citizens are equally represented according to population. o Equal protection requires "one-person-one-vote" for state legislative elections.
Court - Same number of representatives to unequal numbers of constituents. o Alabama's districting scheme which gives the same number of representatives to unequal numbers of constituents is identical in effect and violates its citizens' right to equal protection.
Court - Voter dilution impairs the 14th amendment o Alabama's scheme weighs some votes more than others based upon where the voters live within the State. o It thereby dilutes some of its citizens' votes. o This dilution based on place of residence impairs basic constitutional rights under the 14th Amendment just as much as invidious discrimination based upon factors such as race or economic status. |
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Book Name |
Constitutional Law : Stone, Seidman, Sunstein, Tushnet. ISBN: 978-0-7355-7719-0 |
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Issue |
o Whether a State must elect and apportion its own legislature according to population? Yes. |
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Procedure |
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Trial |
o United States District Court for the Middle District of Alabama, which held invalid, under the Equal Protection Clause, the existing and legislatively proposed plans for the apportionment of seats in the two-house Alabama Legislature and which ordered a temporary reapportionment plan |
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Supreme |
o Affirmed |
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Facts/Cases |
Discussion |
Key Phrases |
Rules/Laws |
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Pl - Reynolds Df - Sims
Description o Reynolds involved Alabama, Colorado, Delaware, Maryland, New York, and Virginia. o There had been no reapportionment of seats in the Alabama Legislature in over 60 years. o This resulted in the perpetuated scheme of enabling a minority stranglehold on the State Legislature. o The voting scheme did not change over time to reflect the increase of population in the districts.
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Chief Justice Warren o A determinative factor in analyzing whether Alabama's districting scheme constitutes invidious discrimination in violation of its citizens' equal protection rights is the fact that the right to vote is an individual right and personal in nature. o The right to vote is a fundamental matter in a free and democratic society.
Aim of legislative apportionment o The achieving of fair and effective representation for all citizens
Court - EPC guarantees opportunity for equal voting o We conclude that the Equal Protection Clause guarantees the opportunity for equal participation by all voters in the election of state legislators.
Court - Same number of representatives to unequal numbers of constituents. o Alabama's districting scheme which gives the same number of representatives to unequal numbers of constituents is identical in effect and violates its citizens' right to equal protection.
Court - Voter dilution impairs the 14th amendment o Alabama's scheme weighs some votes more than others based upon where the voters live within the State. o It thereby dilutes some of its citizens' votes. o This dilution based on place of residence impairs basic constitutional rights under the 14th Amendment just as much as invidious discrimination based upon factors such as race or economic status.
Court - Impossible for representation to be exact, but it must be legitimate o Although it may be a practical impossibility to have representation exactly correspond to population, any divergence from the population standard must be based on legitimate consideration of implementing rational state policy. o The factors of history, area, or economic or other sorts of group interests, are not sufficient reasons for a State to deviate from apportioning its legislature according to its population.
Affirmed
Dissent - Justice Stewart o As long as a State's apportionment plan reasonably achieves, in light of the State's own characteristics, effective and balanced representation of all substantial interests, without sacrificing the principle of effective majority rule, that plan cannot be considered irrational.
Equal protection demands two basic attributes of any plan. o First, it demands that, in light of the State's own characteristics and needs, the plan must be a rational one. o Second, it demands that the plan must be such as not to permit the systematic frustration of the will of a majority of the electorate of the State. |
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Rules |
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Rule o A State must structure its elections and its state legislature so that its citizens are equally represented according to population. o Equal protection requires "one-person-one-vote" for state legislative elections.
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Class Notes |
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