Legal Definitions - Reynolds v. Sims (1964)

Reynolds v. Sims is a landmark 1964 Supreme Court case that established the fundamental principle of "one person, one vote" for state legislative districts. The Court ruled that the Equal Protection Clause of the Fourteenth Amendment requires that seats in both chambers of a state legislature must be apportioned based on population. This means that each person's vote should carry roughly the same weight, regardless of where they live within the state.

The decision aimed to prevent situations where legislative districts had vastly different populations, leading to votes in less populated areas having disproportionately more influence than votes in more populated areas. By mandating population-based apportionment, the Court ensured that all citizens have an equal voice in their state government.

Here are some examples illustrating the application of Reynolds v. Sims:

• Example 1: Outdated Districting in a Growing State

  Imagine a state that hasn't redrawn its legislative districts in several decades. Over this time, a significant portion of its population has moved from rural areas to a few major metropolitan centers. As a result, a rural district with 60,000 residents might elect one state senator, while an urban district containing 600,000 residents also elects just one state senator.

  This scenario directly violates the "one person, one vote" principle established in Reynolds v. Sims. The votes of individuals in the less populated rural district carry ten times the weight of votes cast by individuals in the densely populated urban district, undermining the equal protection of voting rights.

• Example 2: Intentional Malapportionment in a New Plan

  Consider a state legislature proposing a new districting plan where several districts in the northern part of the state, which are predominantly rural and have an average population of 75,000, are each allocated one representative. Meanwhile, districts in the southern, highly urbanized part of the state, with an average population of 250,000, are also allocated one representative each.

  This proposed plan would be unconstitutional under Reynolds v. Sims. It creates a system where a vote cast in a rural northern district has significantly more influence than a vote cast in an urban southern district, failing to ensure that all citizens have an equal voice in their state government.

• Example 3: Geographic vs. Population-Based Representation

  A state's historical practice dictates that its House of Representatives must include at least one representative from each of its 50 counties, regardless of population. Some counties have fewer than 20,000 residents, while others have over 1,000,000. After allocating one representative per county, the remaining seats are distributed based on population.

  This system would likely face a challenge based on Reynolds v. Sims. While the intent might be to ensure representation for all geographic areas, the initial allocation of one representative per county, irrespective of population, means that votes in sparsely populated counties are given disproportionately greater weight than votes in densely populated counties, violating the "one person, one vote" standard for state legislative bodies.