Significance: During the 1960s, the Supreme Court ruled that representation in state legislatures had to be based on population. Reynolds v. Sims was the most important of these "Reapportionment Cases" and provided the philosophy behind the Court's decisions. Because of this ruling, all states had to change their methods for electing legislators.
Background: In 1961 M. O. Sims and other voters in Jefferson County, Alabama, challenged the apportionment of their state legislature. According to the state constitution, the legislature had to be reapportioned every ten years. However, the last time the Alabama legislature had been readjusted for population change was in 1901, after the 1900 federal census. In the next sixty years, the population of Alabama had changed dramatically. By keeping the old voting districts, white Alabamians were able to prevent the election of African Americans to the state legislature. Sims and the other voters argued that this situation violated the equal protection clause of the Fourteenth Amendment.
Decision: This case was argued on November 13, 1963, and decided on June 15, 1964, by a vote of 8 to 1. Chief Justice Earl Warren spoke for the Court. Justice John Harlan dissented. Warren argued that the equal protection clause of the Fourteenth Amendment required that each citizen's vote have equal weight in determining an election. He rejected the notion that counties in states were the same as states in the federal system. Thus, states could not use electoral colleges to elect legislators but had to apportion voting districts according to population. The Court did not provide strict guidelines for reapportionment, which led other voters to bring similar cases to the Court. In his dissent, Harlan argued that courts were not the place to correct social ills.
Excerpt from the Opinion of the Court: “Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests. As long as ours is a representative form of government, and our legislatures are those instruments of government elected directly by and directly representative of the people, the right to elect legislators in a free and unimpaired fashion is a bedrock of our political system. . . . 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 practicable.”
