The U.S. Supreme Court in "Davis v. Mann" and "Reynolds v. Sims" invalidated the unequal voting district apportionment relied upon by the Byrd Organization; Byrd made no plan or significant effort to reverse the organization's decline. Indeed, Byrd from the outset was intent on forging his own political path. In the state senate, he shepherded the Automatic Income Reduction Act, which guaranteed a tax rebate or credit to citizens whenever the general fund surplus exceeded certain levels. In just three years tens of millions of dollars were returned to Virginia taxpayers. Also in 1965, redistricting occurred as required by the Supreme Court decisions. Byrd's former 24th senatorial district, which included the counties of Clarke, Frederick and Shenandoah, as well as the city of Winchester, became the 21st District, as Loudoun County was added.