Reynolds v. Sims (1963)
- Docket
- 23
- Decided
- 1963-01-01
- Category
- General
Summary
Question: Did Alabama's apportionment scheme violate the Fourteenth Amendment's Equal Protection Clause by mandating at least one representative per county and creating as many senatorial districts as there were senators, regardless of population variances? Conclusion: Equal protection requires that state legislative districts should be comprised of roughly equal populations if possible. In an 8-to-1 decision authored by Justice Earl Warren, the Court upheld the challenge to the Alabama system, holding that Equal Protection Clause demanded "no less than substantially equal state legislative representation for all citizens...." Noting that the right to direct representation was "a bedrock of our political system," the Court held that both houses of bicameral state legislatures had to be apportioned on a population basis. States were required to "honest and good faith" efforts to construct districts as nearly of equal population as practicable. Justice Stewart concurred, agreeing with Warren that the Court could intervene to address egregious situations of misapportionment, Stewart sought to limit the application of this decision to clear violations of equal protection. He felt wary of imposing specific guidelines on states for how to redraw the district lines or setting a certain range of ratios that would be acceptable. Justice Harlan dissented, applying an originalist interpretation of the Fourteenth Amendment, which in his opinion had not been meant by the drafters to protect voting rights. He suggested that the Court was intruding on federalism principles protecting the states in their control of local matters. Justice Clark concurred in a separate opinion.