Reynolds v. Sims
Citation and Court
377 U.S. 533 (1964). United States Supreme Court. Chief Justice Warren, writing for the Court (8-1).
Facts
Alabama’s state legislative apportionment, derived largely from a 1901 plan, gave rural counties disproportionate representation relative to their populations. Some urban legislative districts had more than forty times the population of rural districts, yet both had identical legislative representation. Alabama voters from underrepresented districts challenged the apportionment as a violation of the Equal Protection Clause. The district court found the plan unconstitutional and ordered a reapportionment.
Issue
Does the Equal Protection Clause require that seats in both houses of a bicameral state legislature be apportioned substantially on a population basis?
Holding
Yes. The Equal Protection Clause demands that seats in both chambers of a state legislature be apportioned on a population basis. Diluting a citizen’s vote because of where they live violates equal protection just as surely as racial discrimination.
Rule / Doctrine
One Person, One Vote: The Equal Protection Clause requires that legislative districts be drawn so that each citizen’s vote is approximately equal in weight to every other citizen’s vote. Both houses of a bicameral state legislature must be apportioned substantially according to population. The federal analogy — where the Senate gives equal representation to states regardless of population — does not apply to state legislatures, because counties and districts are not sovereign entities.
Significance
Reynolds v. Sims is the constitutional foundation of the “one person, one vote” principle that governs all legislative apportionment in the United States. It built on the justiciability holding of Baker v. Carr and transformed American electoral politics, shifting power from rural to urban and suburban areas. Chief Justice Warren called it the most important decision of his tenure. The principle has since been extended to local governments and has shaped decades of redistricting litigation.