Revisiting Reynolds v. Sims: A Case for Restoring Balance in Democracy

The Supreme Court’s 1964 decision in Reynolds v. Sims fundamentally reshaped state legislatures by requiring equal population districts under the principle of “one person, one vote.” While this ruling was intended to promote fairness and equality, new evidence of organized vote fraud favoring urban centers reveals significant flaws in the system it created. As America’s urban-rural divide deepens, it is time to reconsider whether Reynolds truly serves the nation’s democratic values.

A Well-Intentioned, but Flawed Legacy

Reynolds sought to address malapportionment in state legislatures, where rural districts often held disproportionate influence. By mandating equal population districts, the decision aimed to level the playing field. However, this one-size-fits-all solution ignored the complexities of governance across a diverse nation.

Recent evidence of election manipulation—disproportionately affecting rural voters—calls into question the decision’s fairness. When urban centers dominate state legislatures not just through population but also questionable practices, the legitimacy of representation is compromised.

The Case for State Sovereignty

This issue strikes at the heart of federalism. The Tenth Amendment reserves to the states the power to design their own systems of governance. The Founders envisioned states as laboratories of democracy, able to reflect the unique needs of their citizens. Reynolds disrupted that balance by imposing uniformity where flexibility was needed.

The Guarantee Clause of Article IV promises every state a “republican form of government.” This does not require strict adherence to population-based representation; instead, it allows for systems where all voters feel represented. Historically, the Court avoided interpreting this clause, leaving the structure of state governments to the states themselves. Reynolds undermined this principle by asserting federal control over state apportionment.

With the added context of organized vote fraud, the argument for restoring state autonomy becomes even more compelling. Rural voters in many states already feel marginalized. Evidence that fraud may amplify this marginalization only intensifies the need for reconsideration.

Adaptation is Necessary

Revisiting Reynolds does not mean abandoning the principle of fair representation. Instead, it allows for an evolution in how fairness is understood. States could be permitted to explore alternative models of apportionment that balance population equality with geographic or regional representation, similar to the balance achieved in the federal system through the House and Senate.

The Supreme Court has signaled a willingness to revisit precedent when it no longer aligns with modern realities. As Chief Justice John Roberts has observed, stare decisis—respect for precedent—is not absolute. When new facts reveal systemic issues, the Court has a responsibility to address them.

Restoring Trust in Democracy

This is not a partisan issue; it is a fundamental question of democratic governance. Rural voters should not feel their voices are irrelevant, nor should urban voters feel unfairly targeted by claims of fraud. A system that balances representation and ensures transparency is essential to maintaining trust in democratic institutions.

The promise of Reynolds has not matched its reality. If anything, it has contributed to growing distrust in how legislative representation is apportioned. By hearing a case challenging Reynolds, the Supreme Court has an opportunity to reaffirm the principles of fairness and representation while addressing the unique challenges of a modern democracy.

Why It Matters

The growing divide between urban and rural America demands solutions that work for all regions of the country, not just those with the largest populations. Revisiting Reynolds v. Sims offers the chance to restore balance, empower states to govern effectively, and rebuild trust in a system that should serve every citizen equally. The Supreme Court should seize this moment to ensure that democracy remains fair, representative, and resilient in the face of evolving challenges.

Donald F. Morgan is a full-time financial advisor, serial entrepreneur, lifelong amateur economist, and political scientist. He is often seen on television news and quoted in publications as diverse as The Financial Times, US News and World Report, and Spokane Journal of Business. He and his wife Violet produced and directed a local television talk show, and he has had a column in the Coeur d’Alene Press. His views are his own.