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Reynolds v. Sims

Supreme Court of the United States · 1964 · Constitutional Law

equal protectionreapportionmentone person one votestate legislative apportionmentvoting rightsEqual Protection Clausestate legislaturesvote dilution

Facts

Alabama had not reapportioned its legislature since 1901, despite state constitutional provisions requiring decennial reapportionment and representation based on population. By 1960, severe population shifts produced extreme disparities: only about 25% of the state's population lived in districts electing a majority of either legislative house, with senate variances up to about 41-to-1 and house variances up to about 16-to-1 under the existing plan. After this suit was filed, the Alabama Legislature adopted two plans to take effect in 1966: a proposed constitutional amendment giving each county one senator and at least one representative, and the Crawford-Webb Act, which also substantially favored counties over population. The district court held all three plans invalid and ordered a temporary plan using the House provisions from the proposed amendment and the Senate provisions from the Crawford-Webb Act.

Issue

Does the Equal Protection Clause permit a state to apportion one or both houses of its bicameral legislature on a basis other than population so that votes in different parts of the state carry substantially unequal weight? More specifically, were Alabama's existing apportionment and its two proposed plans constitutionally invalid, and could the federal court grant affirmative relief after finding unconstitutional malapportionment?

Rule

The Equal Protection Clause requires that seats in both houses of a bicameral state legislature be apportioned on a population basis. A State must make an honest and good faith effort to construct districts in both houses as nearly of equal population as is practicable; while mathematical exactness is not required and some deviations may be permissible if grounded in legitimate, rational state policies, population must remain the controlling consideration and the vote of any citizen must be approximately equal in weight to that of any other citizen in the State.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The State of Franklin has a bicameral legislature. After the latest census, it redraws the lower house into districts with nearly equal populations, but it gives each county one seat in the senate even though some counties have twenty times the population of others.

A voter from Columbus, Franklin sues under the Equal Protection Clause. Which is the strongest argument for the voter?

Explanation. Equal Protection requires seats in both houses of a bicameral state legislature to be apportioned on a population basis. A state may not satisfy the Constitution by making only one chamber population-based while assigning the other by county equality. The governing principle is that legislators represent people, not political subdivisions, and substantial dilution of votes in one chamber is unconstitutional.