Reynolds v. Sims [1964]
377 U.S. 533 · Supreme Court of the United States · United States
Issue
Whether the Equal Protection Clause of the Fourteenth Amendment requires that seats in both houses of a bicameral state legislature be apportioned on a population basis.
Held
Yes. The Equal Protection Clause requires that the seats in both houses of a bicameral state legislature be apportioned substantially on a population basis, so that each person's vote carries approximately equal weight.
Exam use
Summary
Whether the Equal Protection Clause of the Fourteenth Amendment requires that seats in both houses of a bicameral state legislature be apportioned on a population basis.
Facts
Issue
Whether the Equal Protection Clause of the Fourteenth Amendment requires that seats in both houses of a bicameral state legislature be apportioned on a population basis.
Held
Yes. The Equal Protection Clause requires that the seats in both houses of a bicameral state legislature be apportioned substantially on a population basis, so that each person's vote carries approximately equal weight.
Ratio Decidendi
The fundamental principle of representative government is that each citizen should have an equally effective voice in the election of legislators. The Equal Protection Clause demands that the weight of a citizen's vote cannot be made to depend on where he lives. Deviations from population equality must be justified by a legitimate state interest, but the federal analogy (where the Senate represents states equally) is not applicable to state legislatures. Both houses must be apportioned on a population basis.
Reasoning
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Reference to Reynolds v. Sims (377 U.S. 533) strengthens a Local Government Law answer because the case reflects the principle that The fundamental principle of representative government is that each citizen should have an equally effective voice in the election of legislators. The Equal Protection Clause demands that the weight of a citizen's vote cannot be made to depend on where he lives. Deviations from population equality must be justified by a legitimate state interest, but the federal analogy (where the Senate represents states equally) is not applicable to state legislatures. Both houses must be apportioned on a population basis. Applied to a problem question, the case should be used after identifying the issue as Whether the Equal Protection Clause of the Fourteenth Amendment requires that seats in both houses of a bicameral state legislature be apportioned on a population basis. The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.
Underlying Concepts
- equal protection
- one-person-one-vote
- apportionment
- voting rights
- representative government
- population equality
Significance
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