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Reynolds v. Sims

(1964)

Supreme Court of the United States - 377 U.S. 533

tl;dr:

Affirms one person, one vote.

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ICRAIssue, Conclusion, Rule, Analysis for Reynolds v. Sims

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Facts & HoldingReynolds v. Sims case brief facts & holding

Facts:Alabama legislature had a districting scheme based on a 1900...

Holding:The right to suffrage is a fundamental matter in a...

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Reynolds v. Sims | Case Brief DeepDive
Majority opinion, author: Mr. Chief Justice Warren
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The case involves an appeal and two cross-appeals from a decision of the Federal District Court for the Middle District of Alabama. The plaintiffs claimed that the Alabama Legislature violated the Alabama Constitution and the Fourteenth Amendment by failing to reapportion itself decennially, resulting in discrimination against certain counties in the allocation of legislative representation. The Supreme Court found that the proposed apportionment of seats in the Alabama House was reasonable but may have violated the State Constitution. The Court ordered a temporary reapportionment plan for the November 1962 election and retained jurisdiction to ensure a true reapportionment of both Houses of the Alabama Legislature. The Court held that a claim challenging the constitutionality of a state's apportionment of seats in its legislature presented a justiciable controversy subject to adjudication by federal courts. The Court emphasized that every voter is equal to every other voter in their state, regardless of their characteristics. Discrimination of any form, whether simple or sophisticated, is prohibited by the Constitution. Any law that violates the principle of equal representation is unconstitutional. The Supreme Court rejected the proposed 67-Senator constitutional amendment and the Crawford-Webb Act as discriminatory, arbitrary, and irrational, and worsened the discrimination in the Senate. The court found that the different political natures of states and counties make the analogy invalid. The District Court erred in allowing the proposed apportionment plans to stand.

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Opinion (Concurrence), author: Mr. Justice Clark,MR. Justice Stewart.
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The author concurs with the Court's new principle for state legislative apportionment based on equal population, but criticizes the lack of clarity in the meaning of "nearly as is practicable." They suggest that plans violating the Equal Protection Clause due to discrimination should be found in violation. The author agrees with the District Court's finding that Alabama's legislative apportionment plan lacks rationality and violates the Equal Protection Clause. Alabama is allowed to devise its own system of legislative apportionment, while adhering as closely as possible to the apportionments approved by the representatives of the people of Alabama.

Dissenting opinion, author: MR. Justice Harlan
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The dissenting opinion argues that the Equal Protection Clause of the Fourteenth Amendment does not require equal representation in both houses of state legislatures. The author criticizes the Court's reliance on political ideology and failure to consider the Fourteenth Amendment as a whole or its legislative history. The argument presented is that the second section of the Amendment acknowledges that states have the power to limit or deny the right to vote for state legislators. The passage challenges the Court's interpretation of the Amendment and its implications for voting rights, and notes previous decisions of the Court that have been disregarded or silently overruled in the present case. The Supreme Court concludes that the 1966 election of members of the Maryland Legislature should not be conducted pursuant to the existing or any other unconstitutional plan. In the Virginia case, the Virginia Legislature is given an adequate opportunity to enact a valid plan, but if it fails to act promptly, the District Court is to take further action.

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