Reynolds v. Simms
377 U.S. 533 (1964)
Constitutional Topic Areas:
14th Amendment ‘Equal Protection Clause’, Federalism, Appellate Jurisdiction, Apportionment
Case Facts:
In 1961, Alabama’s State Legislative Districts were apportioned using outdated population data from 1900. Given a dramatic population increase to urban areas in Alabama, some districts had as much as a 41:1 difference in eligible voters to other districts. M.O. Sims and other voters from Jefferson County, Alabama challenged this malapportionment by arguing the disproportionate number of voters prevented their ability to participate in a purely republican form of government under the 14th Amendment’s Equal Protection clause. The group of voters sued a number of officials in Alabama, namely Probate Judge B.A. Reynolds. The District Court agreed and ordered a temporary reapportionment to be done before the 1962 general election. The defendants appealed, arguing the District Court lacked jurisdiction to reapportion the state legislature.
Questions:
1. Does Alabama’s apportionment violate the 14th Amendment’s Equal Protection Clause by maintaining districts with unequal population size?
Holding:
1. Yes
Legal Reasoning: Chief Justice E. Warren (8-1)
1. Relying on precedent from Baker v Carr, the 14th Amendment grants equal participation in elections and outlaws any attempt at disadvantaging voters
2. The right to a purely republican form of government is the foundation of our political system. Further, the principle of ‘One Person One Vote’ applies, meaning a malapportioned system of districts deprives voters of their true voting weight
3. States must reapportion districts to attempt a nearly equal population in each district, regardless of district size
Concurrence: Justice P. Stewart
1. While the court could lawfully intervene in egregious cases of malapportionment, the court ought to be restricted to only clear instances where the Equal Protection Clause of the 14th Amendment is violated
2. The court should not draw specific guidelines on how the districts are reapportioned
Dissent: Justice J.M. Harlan II
1. From an originalist interpretation of the 14th Amendment, the framers of the Constitution did not intend for voting rights to be protected
2. The court is intruding on state’s rights via federalism to regulate their own local matters
Significance:
Alabama’s districts had to be reapportioned following the court’s holding. This case led to the saying “one person one vote.” Also, this lead to a wave of apportionment litigation as one or both houses in nearly every state in the country was now considered malapportioned after Reynolds
Reflection:
Critics believed the Supreme Court was meddling within state’s rights because apportionment cases constituted as political questions, which doctrine prohibits the Supreme Court from adjudicating to remain politically neutral. Furthermore, a senator from Illinois proposed legislation to allow disproportionately apportioned districts. Overall, Reynolds broadened the power of the federal government
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