Reynolds involved Alabama,
Colorado, Delaware, Maryland, New York, and Virginia.
There had been no reapportionment of
seats in the Alabama Legislature in over 60 years.
This resulted in the perpetuated
scheme of enabling a minority stranglehold on the State
The voting scheme did not change
over time to reflect the increase of population in the
Chief Justice Warren
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.
The right to vote is a fundamental
matter in a free and democratic society.
Aim of legislative apportionment
The achieving of fair and effective
representation for all citizens
- EPC guarantees opportunity for equal voting
We conclude that the Equal
Protection Clause guarantees the opportunity for equal
participation by all voters in the election of state
- Same number of representatives to unequal numbers of
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.
- Voter dilution impairs the 14th amendment
Alabama's scheme weighs some votes
more than others based upon where the voters live within the
It thereby dilutes some of its
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.
- Impossible for representation to be exact, but it must be
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
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.
Dissent - Justice Stewart
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
Equal protection demands two basic attributes of any plan.
First, it demands that, in light of
the State's own characteristics and needs, the plan must be a
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