Reynolds v. Sims

Brief Fact Summary.

The plaintiffs in Alabama sued various state and political party officials charged with duties in connection with state elections, claiming that the malapportioned state legislature violated the Equal Protection Clause.

Synopsis of Rule of Law.

One person’s vote must be counted equally with those of all other voters in a State in statewide and in congressional elections.

Facts.

The plaintiffs in Alabama sued various state and political party officials charged with duties in connection with state elections, claiming that the malapportioned state legislature violated the Equal Protection Clause. Plaintiffs claimed serious discrimination in the allocation of legislative representation. After the Supreme Court found such a claim justiciable in Baker v. Carr, the district court stated that the inequality of existing representation violated Equal Protection and that the proposed state legislative reapportionment was inadequate.

Issue.

Does the malapportioned state legislature violate the Equal Protection Clause?

Held.

Yes, as a basic constitutional standard, the Equal Protection Clause requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis. An individual’s right to vote for state legislators, however, is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State. Therefore, the malapportioned legislature in Alabama violates the Constitution.

Discussion.

As a federal constitutional requisite both houses of a state legislature must be apportioned on a population basis, meaning that 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 possible. While the history indicates that many States have deviated from the equal-population principle in the apportionment of seats in at least one house of their legislatures, others argue that if the divergences from a strict population standard are based on legitimate considerations incident to the effectuation of a rational state policy, some deviations from the equal-population principle are constitutionally permissible with respect to the apportionment of seats in either or both of the two houses of a bicameral state legislature. However, if, even as a result of a clearly rational state policy, population is submerged as the controlling consideration in the apportionment of seats in the particular legislative body, the right of all of the State’s citizens to case an effective and adequately weighted vote would be unconstitutionally impaired.