Reynolds v. Sims

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Reynolds v. Sims

Argued November 13, 1963
Decided June 15, 1964


Full case name:	Reynolds, Judge, et al. v. Sims, et al.

Citations:	377 U.S. 533; 84 S. Ct. 1362; 12 L. Ed. 2d 506; 1964 U.S. LEXIS 1002

Prior history:	Appeal from the United States District Court for the Middle District of Alabama

Holding

The Court struck down state senate inequality based their decision on the principle of "one man, one vote."

Court membership

Chief Justice: Earl Warren
Associate Justices: Hugo Black, William O. Douglas, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Potter Stewart, Byron White, Arthur Joseph Goldberg

Case opinions

Majority by: Warren
Joined by: Black, Douglas, Brennan, White, Goldberg
Concurrence by: Clark
Concurrence by: Stewart
Dissent by: Harlan

Laws applied

U.S. Const. amend. XIV, Equal Protection Clause

Reynolds v. Sims, 377 U.S. 533 (1964) was a United States Supreme Court case that ruled that state legislature districts had to be roughly equal in population.

Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court went further in order to correct what seemed to it to be egregious examples of malapportionment which were serious enough to undermine the premises underlying representative democracy. Before Reynolds, disparities existed between state senates far greater than disparities in the U.S. Senate. Urban and suburban counties were often drastically underrepresented.

Among the more egregious pre-Reynolds disparities (compiled by Congressman Morris K. Udall):

In the Connecticut General Assembly one House district had 191 people; another, 81,000.
In the New Hampshire General Court one township with three people had a Representative in the lower house; this was the same representation given another district with 3,244. The vote of a resident of the first township was therefore 1,081 times more powerful at the Capitol.
In the Utah State Legislature the smallest district had 165 people, the largest 32,380 (196 times the population of the other).
In the Vermont General Assembly the smallest district had 36 people, the largest 35,000, a ratio of almost 1,000 to 1.
Los Angeles County, California; with 6 million people, had one member in the California State Senate, as did the 14,000 people of one rural county.
In the Idaho Legislature the smallest Senate district had 951 people; the largest, 93,400.
17 members of the Nevada Senate represented as many as 127,000 or as few as 568 people, a ratio of 224 to 1.

The eight justices who struck down state senate inequality based their decision on the principle of "one man, one vote." In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests."

In dissent, Justice John Marshall Harlan II lambasted the Court for ignoring the original intention of the Equal Protection Clause, which he argued did not extend to voting rights. Harlan claimed the Court was imposing its own idea of "good government" on the states, stifling creativity and violating federalism. He pointed out that if Reynolds was correct, then the United States Constitution's own provision for two United States Senators from each state would then be Constitutionally suspect as the fifty states have anything but "substantially equal populations." "One man, one vote" was extended to Congressional (but not Senatorial) districts in 1964's Wesberry v. Sanders.

Reynolds v. Sims set off a legislative firestorm in the country. Senator Everett Dirksen of Illinois led a fight to pass a Constitutional amendment allowing unequal legislative districts. Dirksen warned that

". . .the forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. If they were, the 6 million citizens of the Chicago area would hold sway in the Illinois Legislature without consideration of the problems of their 4 million fellows who are scattered in 100 other counties. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit.."

Dirksen was ultimately unsuccessful.