Reynolds v. Sims

Reynolds v. Sims (377 U.S. 533) was a landmark 1964 United States Supreme Court decision in which the court applied the "one person, one vote" ruling from its previous cases against Alabama's severely malapportioned state legislative districts. The effect of this decision was to grant Alabama citizens equal representation in the state legislature. The case was named for B. A. Reynolds, a Dallas County judge named in the original lawsuit, and M. O. Sims, one of the plaintiffs who filed the suit in the U.S. district court.

U.S. citizens are represented in their state legislatures by the men and women whom they elect to serve them. These representatives reside in and are elected from geographical districts that cover the entire state. The challenge of any representative democracy is to ensure that its citizens have equal representation within the legislative branch. This is achieved by ensuring that the representatives in the legislature are apportioned fairly throughout the state. The process of altering the number of representatives from a given legislative district is called reapportionment. The Supreme Court took the Reynolds case because reapportionment had not occurred in Alabama (or several other states at that time) for many years, which meant some Alabamians were not equally represented in the legislature.

1901 Constitution

The Alabama Constitution of 1901 specifies the method to be used by the state legislature in creating legislative districts and apportioning the representation therein. Essentially, it requires that both Senate and House of Representatives districts be as equal and proportional as possible, mandating that representation in both houses be allocated according to the "number of inhabitants" within the legislative districts. The 1901 Constitution also provides for future population shifts by requiring that the legislative seats be reapportioned every 10 years according to figures provided by the federal census.

In August 1961, a group of young lawyers in Jefferson County filed suit in the Middle District federal court in Alabama against a number of state officials who supervised elections in Alabama. They claimed that the state had violated the Equal Protection Clause of the Fourteenth Amendment because no statewide reapportionment of legislative seats had occurred since the 1901 Constitution was adopted. This, they claimed, effectively made their votes count for less. Two of the district court's three judges— Frank M. Johnson and Richard T. Rives—sided with the plaintiffs in their May 1962 decision, and the case was appealed to the U.S. Supreme Court.

U.S. Supreme Court

On November 13, 1963, the Supreme Court heard oral arguments in the first of six cases that would forever alter the way representatives are apportioned in state legislatures. The court chose the Reynolds case for its lead opinion on the issue because the malapportionment of Alabama's legislature was so egregious.

Writing for a majority of the court in Reynolds v. Sims, Chief Justice Earl Warren noted that Alabama's population had increased from 1.8 million to 3.2 million between 1901 and 1961 and that virtually all of that growth had taken place in urban areas. Because no statewide reapportionment had been conducted since the 1900 federal census, the allocation of seats in the state legislature reflected a heavy bias towards rural areas. For example, both Bullock and Henry counties, each with fewer than 16,000 people, were allocated two seats in the Alabama House. Mobile County, on the other hand, with a population of more than 300,000, had just three representatives. Jefferson County's 600,000 residents were represented by just seven seats.

The Court's Decision

The Supreme Court had little trouble seeing the practical effect of malapportioned legislative districts. One person's vote for a representative from a rural area was much more significant and counted for more politically than the vote of a citizen in an urban areas because representatives from rural areas (where less than 25 percent of Alabamians lived) constituted a majority of the Alabama state legislature. They could thus effectively ensure that rural concerns would trump those of urban areas, where the other 75 percent of the state's population lived. The court concluded its decision by stating simply, "[A]n individual's right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State."

Chief Justice Earl Warren, who presided over a number of landmark cases, always considered reapportionment cases such as Reynolds v. Sims the most important of his tenure on the Supreme Court because they gave citizens the right to participate in their government on equal terms with everyone else, which is the essence of democracy.

Further Reading

  • Baker, Gordon E. The Reapportionment Revolution: Representation, Political Power, and the Supreme Court. New York: Random House, 1967.
  • Cortner, Richard C. The Apportionment Cases. Knoxville: University of Tennessee Press, 1970.

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