What was the significance of Reynolds v Sims?

Answer 1

Reynolds v. Sims, 377 US 533 (1964)

Reynolds v. Sims established the "one man, one vote" rule (also called "one person, one vote") that held state political districts of unequal size resulted in under-representation of some citizens' interests and over-representation of others'. This was considered "unrepublican," per Article IV, Section 4 of the Constitution, and unconstitutional under the Fourteenth Amendment Equal Protection Clause. In order to meet constitutional standards, districts had to be reapportioned so each had approximately equal population.

Wesberry v. Sanders, 376 US 1 (1964), a case heard slightly earlier the same year as Reynolds, applied the equal apportionment principle to Districts of the US House of Representatives.

Both the Wesberry and Reynolds decisions were predicated on the landmark ruling in Baker v. Carr, 369 US 186 (1962), in which the US Supreme Court decided reapportionment of state legislative districts was not a "political question" that should be resolved through legislation. The Court found legislative conflicts of interest raised justiciable issues that could be addressed and resolved by the Federal courts.


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Answer 2

Reynolds v. United States, (1878) was case in which the Mormon church challenged the constitutionality of anti-bigamy laws that prohibited polygamy (having more than one spouse), a practice accepted by the church. Plaintiff George Reynolds said the laws were a violation of his First Amendment right to freedom of religion.

The US Supreme Court held that the law was constitutional, and that Reynolds was not protected from the law by virtue of religious beliefs.

Explanation

Mormons, members of the Church of Jesus Christ of Latter-Day Saints, practiced polygamy (having more than one spouse) in the early days of the church. In the Mormon church, husbands could take multiple wives. Congress, determined to outlaw the practice, passed the Morrill Anti-Bigamy Act of 1862 (not to be confused with the Morrill Land-Grant Act of the same year) targeting not only LDS marriage customs, but also attempting to prevent members of the Church and the institution, from accruing most of the land in Utah Territory.

President Lincoln signed the Act into law, but didn't pursue enforcement, which is just as well because Mormon church members considered the law unconstitutional and ignored it. General O'Connor, Commander of the military base at Fort Douglas, Utah, was explicity instructed not to interfere with Mormon practices, or to challenge any violations of the law.

In 1874, a different Congress renewed interest in ending bigamy and passed the Poland Law, expanding the power of courts to prosecute plural marriage by removing jurisdiction from local probate courts and placing it under federal jurisdiction. The courts' early attempts at litigation were a failure, however, because many of the church leaders had married prior to passage of the 1862 law, and could not be tried ex post facto. Further, wives were exempt from testifying against husbands, and marriage records were held in confidence by the LDS Church.

US Attorney General William Carey and church leaders agreed to temporarily refrain from attempts to prosecute Mormons under the Morrill and Poland Acts until the Church could test the constitutionality of the anti-bigamy laws by bringing a case before the US Supreme Court.

George Reynolds, 32-year-old secretary to Church leader Brigham Young, agreed to be the plaintiff in that challenge. Reynolds had two wives, but complicated the lower court case by keeping the second wife hidden so she couldn't be served with a subpoena to testify. Utah would not have respected the prohibition of forcing a wife to testify against her husband for the second wife, since they didn't consider the second marriage valid.

Reynolds argued that he was practicing his religion, which encouraged polygamy. He contended that the federal law against polygamy was an unconstitutional violation of the First Amendment Free Exercise Clause, and interfered with his ability to practice his religion. Reynolds further argued that the Grand Jury indictment was invalid because the territory only empaneled fifteen jurors, instead of the customary sixteen (in fact, Utah Territory required only fifteen Grand Jury members, so the argument was moot).

In 1875, Reynolds was found guilty in US District Court, and sentenced to two years hard labor with a $500 fine. The law provided for a maximum penalty of five years in prison.

Reynolds appealed his case to The Supreme Court of the Territory of Utah, the highest appellate court within that federal area. The Utah Court affirmed the lower court ruling in toto. Reynolds next appealed to the US Supreme Court.

Supreme Court Decision

Reynolds attorney contested not only the constitutionality of the Utah courts' ruling, but the instructions the judge provided the jury for deliberation purposes. The LDS contingent had wanted to judge to tell the jury Reynolds was entitled to an acquittal because he was acting on what he believed to be his religious duty.

Chief Justice Waite, delivering the opinion of the Court, addressed both concerns:

"A party's religious belief cannot be accepted as a justification for his committing an overt act, made criminal by the law of the land. Where, therefore, the prisoner, knowing that his wife was living, married again in Utah, and, when indicted and tried therefor, set up that the church whereto he belonged enjoined upon its male members to practise polygamy, and that he, with the sanction of the recognized authorities of the church, and by a ceremony performed pursuant to its doctrines, did marry again -- held, that the court properly refused to charge the jury that he was entitled to an acquittal although they should find that he had contracted such second marriage pursuant to, and in conformity with, what he believed at the time to be a religious duty."

"The court told the jury to "consider what are to be the consequences to the innocent victims of this delusion [the doctrine of polygamy]. As this contest goes on, they multiply, and there are pure-minded women and there are innocent children -- innocent in a sense even beyond the degree of the innocence of childhood itself. These are to be the sufferers; and as jurors fail to do their duty, and as these cases come up in the Territory of Utah, just so do these victims multiply and spread themselves over the land."

"Held, that the charge was not improper. "

Their decision considered the protection of the family as a legitimate use of law creating an exception to the First Amendment. The Court held the Free Exercise Clause was never intended as protection against acts damaging to the "morals of society."

The Court initially affirmed the Supreme Court of Utah Territory's ruling, but reversed and vacated the sentence on discovery that the Anti-bigamy law provided only for fines and imprisonment, but said nothing about "hard labor." The case was remanded to the lower court for resentencing, but the constitutionality of the Morrill Anti-Bigamy Act was upheld.

Epilogue

Reynolds had been imprisoned in Utah Territory since June 1876. After the Supreme Court upheld his conviction, but vacated the requirement for hard labor, Reynolds sentence was increased from two years imprisonment to five. He was released from the Utah Penitentiary on January 20, 1881, five months early for good behavior.

Reynolds married his third and final wife, Mary Goold, on April 25, 1885, but was never charged with a second violation of the Anti-bigamy law.

In 1890, Church President Wilford Woodruff officially ended the practice of polygamy, and ordered church members to comply with federal law.

Reynolds v. United States, (1878) has never been overturned, although certain laws restricting activities (other than polygamy) of the LDS Church have since been revoked.

Case Citation:

Reynolds v. United States, 98 US 145 (1878)

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Answer 3

Reynolds v. Sims, 377 US 533 (1964)

Reynolds v. Sims established the "one man, one vote" rule (also called "one person, one vote") that held state political districts of unequal size resulted in under-representation of some citizens' interests and over-representation of others'. This was considered "unrepublican," per Article IV, Section 4 of the Constitution, and unconstitutional under the Fourteenth Amendment Equal Protection Clause. In order to meet constitutional standards, districts had to be reapportioned so each had approximately equal population.

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Answer 4

The case was originally brought in US District Court by voters of Jefferson County, Alabama, in response to voting district apportionment designed by the Alabama legislature and allowed under the state constitution. The districting favored rural interests over urban interests.

Case Citation:

Reynolds v. Sims, 377 US 533 (1964)

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Answer 5

Yes, Reynolds v. Sims, 377 US 533 (1964) was a US Supreme Court case.

If the question asks whether it was proper for the Supreme Court to hear Reynolds v. Sims, because voting district apportionment is typically a political or states' rights question, the answer is also yes. Many states, including Alabama where Reynolds v. Sims originated, assigned legislative representation according to geographical boundaries. This resulted in people living in low-density population areas (rural) having more representatives per capita than those living in high-density (urban) areas. The inequity ensured rural interests took priority over urban interests by granting more power to rural (typically white) voters. Some Alabama Senatorial districts had 41 times more voters than others.

The Supreme Court had deferred to the states on the issue of unequal representation in the past, believing the State legislatures should seek their own solution. When the states failed to address the inequality, the Court decided the matter was justiciable (could be remedied by the courts) under the Fourteenth Amendment Equal Protection Clause.

The phrase "one man, one vote" (or "one person, one vote") originated from the decision in Reynolds v. Sims, when the Supreme Court voted 8-1 that districts had to be reapportioned so that each contained approximately the same population, ensuring fair representation for each voter.

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