Brief Fact Summary. The Plaintiffs alleged that the last apportionment of the Alabama legislature was based on the 1900 federal census and that the population growth in the intervening six decades has now made representation discriminatory against areas with fast-growing populations.
Synopsis of Rule of Law. In most instances, districts should be apportioned to allow each voter to have one, undiluted vote.
Issue. Is the current system of apportionment denying to Alabama voters the equal protection of laws?
The Supreme Court of the United States (Supreme Court) notes that “[l]egislators represent people, not trees or acres.” If the State gives voters in one part of the State much more weight in the vote of their legislators, the right to vote of voters in underrepresented parts of the State has been diluted.
Although the federal legislature has a separate apportionment for its two houses, there is no such need at the State level. Hence, apportionment of state legislatures needs to reflect a one-person, one-vote policy.
Dissent. Justice John Marshall Harlan (J. Marshall) argues that States should be allowed to determine the composition of their legislatures on their own and that this is a political question, lying outside the reach of the Supreme Court.
Discussion. Reynolds v. Sims establishes the principle apportionment doctrine of the United States Constitution (Constitution): one-person, one-vote. The Supreme Court gets around the non-justiciability of political questions by framing the argument as an Equal Protection issue: “To the extent that a citizen’s right to vote is debased, he is that much less a citizen.”