Reynolds v. Sims

Brief Fact Summary.

Voters from Jefferson County, Alabama challenged the apportionment of the Alabama Legislature because the Alabama Constitution provided that there be only one state senator per county, resulting in extreme ratio variances as great as 41:1 from one senatorial district to another.

Synopsis of Rule of Law.

The Equal Protection Clause of the Fourteenth Amendment requires that the legislative districts across states be equal in population.

Facts.

In Jefferson County, Alabama, home to the state’s largest city of Birmingham, lines dividing electoral districts resulted in dramatic population discrepancies among the districts. The state constitution required at least one representative per county and senatorial district. However, the district in Jefferson County contained 41 times as many eligible voters as those in another district of the state. Plaintiffs argued that this lack of proportionality prevented them from effectively participating in a republican form of government.

Issue.

Did Alabama’s apportionment scheme violate the Equal Protection Clause?

Held.

Yes, Alabama’s apportionment scheme violated the Equal Protection Clause.

Dissent.

Justice Harlan

The consequence of today’s decision is that the courts are given blanket authority to supervise apportionment of state legislatures. It is difficult to imagine a more intolerable and inappropriate interference by the judiciary with the independent legislatures of the states.

Discussion.

The Equal Protection Clause demands no less than substantially equal state legislative representation for all citizens. The right to direct representation is a bedrock of our political system and both houses of bicameral state legislatures have to be apportioned on a population basis. It is inconceivable that a state law would result in the votes of citizens in one part of the state to be multiplied by 2, 5, or 10, while the votes of persons from another part of the state would be counted only at face value. Diluting the weight of votes because of place of residence impairs basic constitutional rights, as much as invidious discrimination based upon race or economic status. Thus, the Equal Protection Clause requires that a state make an honest and good faith effort to construct districts, in both houses of its legislature, as nearly of equal population as is practicable.The Equal Protection Clause demands no less than substantially equal state legislative representation for all citizens. The right to direct representation is a bedrock of our political system and both houses of bicameral state legislatures have to be apportioned on a population basis. It is inconceivable that a state law would result in the votes of citizens in one part of the state to be multiplied by 2, 5, or 10, while the votes of persons from another part of the state would be counted only at face value. Diluting the weight of votes because of place of residence impairs basic constitutional rights, as much as invidious discrimination based upon race or economic status. Thus, the Equal Protection Clause requires that a state make an honest and good faith effort to construct districts, in both houses of its legislature, as nearly of equal population as is practicable.