Reynolds v. Sims

1964-10-12

Headline: Ruling requires “one person, one vote”: Court strikes down Alabama’s legislative maps and orders both state legislative houses apportioned by population, reducing rural overrepresentation and shifting political power to population centers.

Holding: The Court held that the Equal Protection Clause requires both houses of every state legislature be apportioned on a population basis and affirmed the lower court’s invalidation of Alabama’s existing and proposed plans.

Real World Impact:

Requires states to reapportion both legislative houses by population.
Allows federal courts to order temporary maps when legislatures fail.
Shifts power from overrepresented rural counties to urban and suburban voters.

Topics: state legislature apportionment, one person one vote, voting equality, reapportionment, Alabama elections

Summary

Background

A group of Alabama voters from Jefferson and other counties sued, saying the State’s 1901 apportionment left rapidly growing counties underrepresented. A three-judge federal court found the existing plan and two legislative fixes (a “67‑Senator” amendment and the Crawford‑Webb Act) unconstitutional and put a temporary plan in place for the 1962 elections.

Reasoning

The key question was whether the Fourteenth Amendment’s Equal Protection Clause requires state legislative districts to be based on population. The Court said yes: voters must have substantially equal weight in electing both houses of a bicameral state legislature. The Justices rejected the idea that state county lines justify large population disparities and declined to apply the Federal Senate analogy. The Court therefore affirmed the lower court’s invalidation of Alabama’s existing and proposed plans and approved the temporary remedy while giving the legislature a chance to adopt a lawful permanent plan.

Real world impact

The decision forces states with malapportioned legislatures to redraw both chambers on a population basis, weakens longstanding rural overrepresentation, and makes judicially imposed temporary maps an available remedy when legislatures fail to act in time for scheduled elections. The Court kept jurisdiction so courts can review whether a subsequently enacted plan meets the population requirement.

Dissents or concurrances

A concurrence warned the Court went beyond what was necessary to invalidate Alabama’s “crazy‑quilt” maps. A strong dissent argued the ruling was judicial overreach and disputed the use of the Fourteenth Amendment to impose this rule on all States.