Voters from Jefferson County, Alabama challenged the apportionment structure of their State House and Senate, which required each county to have at least one representative, regardless of size. This system failed to take population size into account, leading to huge discrepancies between district populations, in some cases on the order of 41 to 1. Senators were also apportioned under a system that incorporated geography into its formula, leading again to the under-representation of those in urban counties and over-representation of those in small and rural counties. Under this system Jefferson County, with a population of over 600,000, received only 1 senator and 7 representatives, while other counties with populations as low as 15,417 also received one senator, along with one Representative. In light of these discrepancies, the District Court found that there was an equal protection violation. The Court chose to allow the legislature the opportunity to solve the problem itself, but upon finding the newly proposed apportionment plans were still unsatisfactory, it ordered a new temporary apportionment plan created by the Court itself for use in the upcoming 1962 general election. The State appealed the decision, arguing that it was not prohibited from using geography in it apportionment formulation and that the District Court had overstepped its power in drafting its own apportionment plan. The case came before the Supreme Court.
The Court struck down Alabama’s apportionment system as unrepresentative, reaffirming its ruling in Baker and Gray that the debasement or dilution of one’s vote in State elections constitutes a justiciable violation of the Equal Protection Clause. The majority opinion, written by Chief Justice Warren, went further than these cases by expounding what the Court meant by “discoverable and manageable standards for use by lower courts [when] determining the constitutionality of a state legislative apportionment scheme.” The Court declared that “The Equal Protection Clause demands no less than substantially equal state legislative representation for all citizens,” which it had determined in Gary v. Sanders should aim to achieve the ideal of “one person, one vote.” The court did note, however, that more flexibility might be permissible in State apportionment than for congressional districts. Furthermore, giving voice to political subdivisions might in some cases justify a degree of deviation from purely population based apportionment. Also, “a State may legitimately desire to construct districts along political subdivision lines to deter the possibilities of gerrymandering.” Similarly, reapportionment might not necessarily have to take place every ten years, though longer periods between reapportionment would be treated as suspect. In explaining the Court’s position, Chief Justice Warren included the famous line, “Legislators represent people, not trees or acres.” The Court also dismissed the claim that states’ apportionment systems could mirror that of the Federal Senate, claiming that the unique political needs that required that system of apportionment were not applicable on the state level. The Court also ruled that the District Court had acted properly in issuing its own, temporary apportionment plan.
Impact on Redistricting
Reynolds would have huge repercussions for State governments, a fact immediately recognized around the country. The reaction to this decision was so powerful that a constitutional amendment was unsuccessfully proposed to allow States to have unequal districts. To many, the idea that the Federal government could have a geographically based apportionment system but that states could not seemed illogical. Regardless, the decision stood, and State governments around the country would be forced to change their apportionment systems to approximate the one-person one-vote principle. The case also set an important precedent for allowing Courts to step in and enforce their own redistricting plans when they found the legislature’s plans to be objectionable.