Thursday, November 14, 2013

Reynolds v. Sims case brief

Reynolds v. Sims case brief summary
377 U.S. 533 (1964)

Appellant political party officials and cross-appellant intervening voter groups sought review of a decision from the United States District Court for the Middle District of Alabama, which held invalid, under the Equal Protection Clause, the existing and legislatively proposed plans for the apportionment of seats in the two-house Alabama Legislature and which ordered a temporary reapportionment plan.

The original plaintiffs, county residents, taxpayers, and voters, alleged that despite uneven population growth from 1900 to 1960, the failure of the Alabama legislature to reapportion itself denied them equal suffrage in free and equal elections and the equal protection of the law, in violation of U.S. Constitutional Amendment XIV.


  • The court affirmed the judgment of the district court, which held that the existing and two legislatively proposed plans for the apportionment of seats in the two houses of the Alabama legislature were invalid. 
  • The court held that the Equal Protection Clause required both houses of a bicameral state legislature to be apportioned on a population basis and that recourse to the so-called "federal analogy" would not be sustained. 
  • The district court was found to have acted with proper judicial restraint after the Alabama legislature failed to act effectively to remedy the constitutional deficiencies in its apportionment scheme in ordering its own temporary plan to permit the holding of elections pursuant to it without great difficulty and in retaining jurisdiction and deferring a hearing on a final injunction to allow the legislature opportunity to act effectively.
The court affirmed the district court's decision to invalidate existing and proposed plans for the apportionment of Alabama's bicameral legislature because the plans violated the Equal Protection Clause. Any such apportionment was to be based on population, and recourse to the "federal analogy" would not be sustained. The plan effected by the district court to allow for interim elections while the legislature acted was affirmed.

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