Reynolds v. Sims

Explanation and Analysis of the Document

Despite the protections of the Fourteenth Amendment, black voters continued to be disenfranchised in the South through the 1950s. Disenfranchisement took many forms, including literacy tests and poll taxes. The process of apportionment, which determined the boundaries of congressional districts, also effectively disenfranchised voters, particularly those who lived in urban areas. Even though many states' populations were shifting from the country to the city, most states continued to allocate representatives by county, which effectively robbed urban voters of proportional representation in their legislatures. Rural interests thus governed increasingly urban populations.

In 1959 Charles Baker and nine other urban residents sued the Tennessee secretary of state, Joe C. Carr, noting that the state had not reapportioned its districts since 1901 and had thus effectively denied its urban voters their Fourteenth Amendment rights. Baker v. Carr represented a challenge to the Warren Court. First of all, the courts had traditionally shied away from matters involving political districting, concerned that judicial rulings in this area could be construed as a violation of separation of powers; legislative questions were considered political matters not appropriate for Court involvement. Furthermore, the right to vote is not clearly established by the Constitution. The Founders had a restrictive view of who should be able to vote: Slaves, women, and unpropertied males were not considered eligible. In considering Baker v. Carr, the Court was entering new territory. Written by William J. Brennan, the 1962 Baker decision was carefully worded, stating only that reapportionment could be taken up in the courts. The ruling thus let individual federal district courts decide how they would solve problems of malapportionment. Soon after the decision was announced, attorneys filed cases challenging apportionments in several states. By the end of 1962, the Supreme Court had twelve cases pending that related to redistricting. These state cases were decided collectively under Reynolds v. Sims on June 15, 1964.

In Reynolds v. Sims, several voters in Alabama sued state election officials, charging that their Fourteenth Amendment rights, as well as their rights under the Alabama Constitution, had been violated by the state's existing legislative apportionment. The case also involved a dispute over proposed reapportionment plans, which the plaintiffs argued were unconstitutional. Having established in Baker v. Carr that the courts did, in fact, have jurisdiction over such matters, the Warren Court now needed to address specific cases handed up by the federal district courts.

In the first paragraph of the excerpt of Warren's decision, he makes clear his opinion that the Court has jurisdiction over questions of redistricting. One of the roles of the Supreme Court is to evaluate the constitutionality of state and federal laws; by stating that the Constitution protects the right of qualified voters, Warren establishes the Court's role in striking down laws that violate those rights.

As was the case in Brown v. Board, Warren's decision in this case was strongly influenced by his attitude toward racial discrimination. He mentions the practice of “gerrymandering,” which is the manipulation of election district boundaries in order to influence election results. The term derives from Elbridge Gerry, governor of Massachusetts from 1810 to 1812, who redistricted the state to benefit his political party. Warren refers to racial gerrymandering, which was practiced in both southern and northern states; by redrawing legislative district lines, politicians could create segregated, all-black districts or, in some cases, eliminate black voters from an area when it was expedient. Warren points out that malapportionment disenfranchises voters just as effectively as prohibiting them from voting at all.

Warren's decisions are noteworthy for their clear, straightforward language. This particular document contains an especially unusual and oft-quoted passage: “Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests.” This verbiage was actually crafted by the law clerk Francis X. Beytagh, who worked on the case with Warren. Warren read this in the draft statement and thought that the language captured the essence of his “one man, one vote” argument. The passage stands out for the very reason that its tone differs from that of the rest of the document.

A key component of Warren's decision is his statement that “seats in both houses of a bicameral state legislature must be apportioned on a population basis.” Important here is the assertion that both houses had to use population as a means of determining representation. Following Baker v. Carr, many states refused to reapportion their districts, instead using what was known as the “federal plan,” in which one house of the legislature was apportioned geographically and the other by population. Reynolds v. Sims made clear that the federal plan was no longer an option. Warren allowed for some flexibility in redistricting in order to prevent gerrymandering or to provide for fair representation in more rural states with many counties. However, he reiterates in his decision that population is the overriding factor that should determine the number of representatives.

Reynolds v. Sims was a much broader decision than Baker v. Carr in the sense that it had a dramatic and lasting impact on the political landscape. By specifically defining constitutional districting plans in terms of population rather than geography, Warren summarily eliminated the jobs of many powerful rural senators and assemblymen; rural districts disappeared as states redrew boundaries to conform to the new requirements. Reynolds v. Sims thus helped end one method of black voter disenfranchisement in America.