Reynolds v. Sims

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

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.

Supreme Court of the United States

377 U.S. 533, 12 L. Ed. 2d 506, 84 S. Ct. 1362, 1964 U.S. LEXIS 1002, SCDB 1963-140

No. 23

1964-06-15

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