time of Reynolds not redistricted since 1901. In Connecticut, Vermont, Mississippi, and Delaware, apportionment was fixed by the states' constitutions, which, when written in the late eighteenth or nineteenth centuries, did not foresee the possibility of rural depopulation as was to occur during the first half of the century. In New Hampshire the state constitutions, since January 1776, had always called for the state senate to be apportioned based on taxes paid, rather than on population. Having already overturned its ruling that redistricting was a purely political question in Baker v. Carr, 369 U.S. 186 (1962), the Court ruled to correct what it considered egregious examples of malapportionment; these were serious enough to undermine the premises underlying republican government. Before Reynolds, urban counties nationwide often had total representations similar to rural counties, and in Florida, there was a limit to three representatives even for the most populous counties. The case Voters from Jefferson County, Alabama, home to the state's largest city of Birmingham, challenged the apportionment of the Alabama Legislature. The Alabama Constitution provided that there be only one state senator per county. Ratio variances as great as 41 to 1 from one senatorial district to another existed in the Alabama Senate (i.e., the number of eligible voters voting for one senator was in one case 41 times the number of voters in another). The case was named for M. O. Sims, one of the voters who brought the suit, and B. A. Reynolds, a probate judge in Dallas County, one of the named defendants in the original suit. Reynolds was named (along with three other probate judges) as a symbolic representative of all probate judges in the state of Alabama. Among the more extreme pre-Reynolds disparities claimed by Morris K. Udall: In the Connecticut General Assembly, one House district had 191 people. In the New Hampshire General Court, one township with three people had a Representative in the lower house; this was the same representation given another district with a population of 3,244. In the Utah State Legislature, the smallest district had 165 people, the largest 32,380. In the Vermont General Assembly, the smallest district had 36 people, the largest 35,000. Los Angeles County, California, then with six million people, had one member in the California State Senate, as did the 400 people of Alpine County. In the Idaho Senate, the smallest district had 969 people; the largest, 93,400.