holding that apportionment of seats in both houses of a bicameral state legislature must be done equally based on population, because “the overriding objective must be substantial equality of population among the various districts, so that the vote of any citizen is approximately equal in weight to that of any other citizen in the State”
How later courts described this case
- holding that apportionment of seats in both houses of a bicameral state legislature must be done equally based on population, because “the overriding objective must be substantial equality of population among the various districts, so that the vote of any citizen is approximately equal in weight to that of any other citizen in the State”
- concluding that *311 “[s]ince the achieving of fair and effective representation for all citizens is concededly the basic aim of legislative apportionment,” a legislature’s reliance on other apportionment interests is invalid, arbitrary, and capricious action if it leads to unequal populations among districts
- concluding that "[s]ince the achieving of fair and effective representation for all citizens is concededly the basic aim of legislative apportionment," a legislature's reliance on other apportionment interests is invalid, arbitrary, and capricious action if it leads to unequal populations among districts
- holding that the district court “acted wisely in declining to stay the impending primary election in Alabama, and properly re‐ frained from acting further until the Alabama legislature had been given an opportunity to remedy the admitted discrepan‐ cies in the State’s legislative apportionment scheme ….”
Written by the judges who cited it.
Later courts went against this
Disagreed with by Opinion of the Justices, 278 Ala. 412 (1965)
While we disagree with these decisions, we are nevertheless bound by them, and the case of Reynolds v. Sims, supra, was from Alabama and Section 199 of our Constitution was one of the sections considered by the Federal Supreme Court in that decision.
Limited by Barnesville Edn. Assn. v. Barnesville Exe., Unpublished Decision (3-6-2007), 2007 Ohio 1109 (2007)
Moreover, the Reynolds Court also limited its holding to statewide elections where all voters are voting for the same candidate or issue.
Distinguished
Distinguished by Carlson v. San Juan County, 183 Wash. App. 354 (2014)
) The other apportionment cases Carlson cites address the “one person, one vote” principle under Reynolds and are inapposite.
Distinguished by State v. FRONTIER ACRES COMMUNITY DEVELOP. DIST. PASCO COUNTY, 10 Fla. L. Weekly 330 (1985)
Thus, the demands of Reynolds were inapplicable.
Distinguished by Foster v. Sunnyside Valley Irrigation District, 102 Wash. 2d 395 (1984)
The Court reasoned that, because the district exercised little governmental authority, the requirements of Reynolds v. Sims, supra, were inapplicable.
Distinguished by Salyer Land Co. v. Tulare Lake Basin Water Storage District, 410 U.S. 719 (1973)
We hold, therefore, that the popular election requirements enunciated by Reynolds, supra, and succeeding cases are inapplicable to elections such as the general election of appellee Water Storage District.
The opinion
Mr. Justice Clark,
concurring in the affirmance.
The Court goes much beyond the necessities of this case in laying down a new “equal population” principle for state legislative apportionment. This principle seems to be an offshoot of Gray v. Sanders, 372 U. S. 368, 381 (1963), i. e., “one person, one vote,” modified by the “nearly as is practicable” admonition of Wesberry v. Banders, 376 U. S. 1, 8 (1964). * Whether “nearly as is *720 practicable” means “one person, one vote” qualified by “approximately equal” or “some deviations” or by the impossibility of “mathematical nicety” is not clear from the majority’s use of these vague and meaningless phrases. But whatever the standard, the Court applies it to each house of the State Legislature.
It seems to me that all that the Court need say in this case is that each plan considered by the trial court is “a crazy quilt,” clearly revealing invidious discrimination in each house of the Legislature and therefore violative of the Equal Protection Clause. See my concurring opinion in Baker v. Carr, 369 U. S. 186, 253-258 (1962).
I, therefore, do not reach the question of the so-called “federal analogy.” But in my view, if one house of the State Legislature meets the population standard, representation in the other house might include some departure from it so as to take into account, on a rational basis, other factors in order to afford some representation to the various elements of the State. See my dissenting opinion in Lucas v. Forty-Fourth General Assembly of Colorado, post, p. 741, decided this date.
MR. Justice Stewart.
All of the parties have agreed with the District Court’s finding that legislative inaction for some 60 years in the face of growth and shifts in population has converted Alabama’s legislative apportionment plan enacted in 1901 into one completely lacking in rationality. Accordingly, for the reasons stated in my dissenting opinion in Lucas v. Forty-Fourth General Assembly of Colorado, post, p. 744, I would affirm the judgment of the District Court holding that this apportionment violated the Equal Protection Clause.
I also agree with the Court that it was proper for the District Court, in framing a remedy, to adhere as closely *721 as practicable to the apportionments approved by the representatives of the people of Alabama, and to afford the State of Alabama full opportunity, consistent with the requirements of the Federal Constitution, to devise its own system of legislative apportionment.
Incidentally, neither of these cases, upon which the Court bases its opinion, is apposite. Gray involved the use of Georgia's county unit rule in the election of United States Senators and Wesberry was a congressional apportionment case.