Reynolds v. Sims
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Reynolds v. Sims, 377 U.S. 533 (1964) was a United States Supreme Court case that ruled that state legislature districts had to be roughly equal in population.
Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court went further in order to correct what seemed to it to be egregious examples of malapportionment which were serious enough to undermine the premises underlying representative democracy. Before Reynolds, disparities existed between state senates far greater than disparities in the U.S. Senate. Urban counties were often drastically underrepresented.
Here are a few pre-Reynolds disparities compiled by then-Arizona Representative Morris K. Udall:
- In Connecticut one House district had 191 people; another, 81,000.
- In New Hampshire one township with three people had a state assemblyman; this was the same representation given another district with 3,244. The vote of a resident of the first township was therefore 108,000 percent more powerful at the Capitol.
- In Utah the smallest district had 164 people, the largest 32,280 (28 times the population of the other).
- In Vermont the smallest district had 36 people, the largest 35,000, a ratio of almost 1,000 to 1.
- In California, Los Angeles County, which had a population of six million, had one state senator, as did the 14,000 people of one rural county.
- In Idaho the smallest Senate district had 951 people; the largest, 93,400.
- Nevada's 17 State senators represented as many as 127,000 or as few as 568 people, a ratio of 224 to 1.
The eight justices who struck down state senate inequality based their decision on the principle of "one man, one vote." In his majority decision, Chief Justice Earl Warren said "Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests."
In dissent, Justice John Marshall Harlan II lambasted the Court for ignoring the original intention of the Equal Protection Clause, which he argued did not extend to voting rights. Harlan claimed the Court was imposing its own idea of "good government" on the states, stifling creativity and violating federalism. He pointed out that if Reynolds was correct, then the United States Constitution's own provision for two United States Senators from each state would then be Constitutionally suspect as the fifty states have anything but "substantially equal populations." "One-man, one vote" was extended to Congressional districts in 1964's Wesberry v. Sanders.
Reynolds v. Sims set off a legislative firestorm in the country. Sen. Everett Dirksen of Illinois led a fight to pass a Constitutional amendment allowing unequal legislative districts. Dirksen warned that if
- ". . .the forces of our national life are not brought to bear on public questions solely in proportion to the weight of numbers. If they were, the 6 million citizens of the Chicago area would hold sway in the Illinois Legislature without consideration of the problems of their 4 million fellows who are scattered in 100 other counties. Under the Court's new decree, California could be dominated by Los Angeles and San Francisco; Michigan by Detroit.."
Dirksen was ultimately unsuccessful.
See also
- Rotten borough, an English phenomenon