Reynolds v. Sims Case Brief

Why is the case important?

A districting scheme that was based on an outdated census and that had a practical effect of discriminating against voters in counties whose populations had grown proportionally far more than others since the 1900 census was held unconstitutional as a violation of equal protection by the Supreme Court of the United States.

Facts of the case

In 1961, M.O. Sims, David J. Vann (of Vann v. Baggett), John McConnell (McConnell v. Baggett), and other voters from Jefferson County, Alabama, challenged the apportionment of the state legislature. Lines dividing electoral districts had 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, which is near Birmingham, contained 41 times as many eligible voters as those in another district of the state. Sims and the other voters argued that this lack of proportionality prevented them from effectively participating in a republican form of government.

Question

Whether this districting scheme violates equal protection.

Answer

“Yes. Judgment of the lower federal court affirmed and remanded for further proceedings. If a state should provide that votes in one part of the state should receive more weight than votes from another part of the state, the right to vote of those in disfavored areas is diluted. With respect to the allocation of legislative representation, all voters, as citizens of the state, stand in the same relation regardless of where they live. So long as the divergences of 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, but neither history alone, nor economic or other sorts of group interests, are permissible factors in attempting to justify disparities from population-based representation. Further, equal protection requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis.
Therefore, this districting scheme violates equal protection.

Discussion. Within a year of the 1962 ruling in Baker v. Carr, suits challenging state legislative apportionment schemes were instituted in over thirty states. This case answered some of the questions left open by Baker.”

Conclusion

“The court held that the Equal Protection Clause required both houses of a bicameral state legislature to be apportioned on a population basis and that recourse to the so-called “”federal analogy”” would not be sustained. The district court was found to have acted with proper judicial restraint after the Alabama legislature failed to act effectively to remedy the constitutional deficiencies in its apportionment scheme in ordering its own temporary plan to permit the holding of elections pursuant to it without great difficulty and in retaining jurisdiction and deferring a hearing on a final injunction to allow the legislature opportunity to act effectively.”

  • Case Brief: 1964
  • Appellant: Reynolds
  • Appellee: Sims
  • Decided by: Warren Court

Citation: 377 US 533 (1964)
Argued: Nov 13, 1963
Decided: Jun 15, 1964