[EL] ELB News and Commentary 12/9/15
Rick Hasen
rhasen at law.uci.edu
Tue Dec 8 21:26:22 PST 2015
“Justices will get no satisfaction with a new ‘one person, one vote’
rule” <http://electionlawblog.org/?p=78170>
Posted onDecember 8, 2015 9:22 pm
<http://electionlawblog.org/?p=78170>byRick Hasen
<http://electionlawblog.org/?author=3>
I have writtenthis oped
<http://www.latimes.com/opinion/op-ed/la-oe-1210-hasen-evenwel-voting-district-20151208-story.html>on
Evenwel for the LA Times oped page. It begins:
At the Supreme Court on Tuesday, the justices struggled over the
meaning of the 1960s-era “one person, one vote” rule. Should Texas
legislative districts contain an equal number of people — as they do
now — or an equal number of eligible voters, as the plaintiffs
inEvenwel vs. Abbott
<http://www.supremecourt.gov/oral_arguments/argument_transcripts/14-940_c07e.pdf>demand?
Ultimately, the justices may have no choice but to heed some other
words written in the 1960s: You can’t always get what you want.
Another snippet:
At the oral argument Tuesday, JusticeAnthony Kennedy
<http://www.latimes.com/topic/crime-law-justice/justice-system/anthony-kennedy-PEPLT00008042-topic.html>tried
to split the difference. He pondered whether Texas — and other
states — could draw districts with an equal number of people and an
equal number of voters. “Why can’t you have both?” he asked Texas
Solicitor General Scott Keller.
And this is where the Rolling Stones principle comes in: A total
population standard isn’t what everyone wants, but it’s what we need
to avoid chaos.
A legislative map equalizing both total voters and total population
would violate all sound redistricting principles, breaking up
cities, separating communities of interests and producing grotesque
shapes. Indeed, after Keller made these points, Kennedy seemed to
concede the point: “That sounds highly probable to me.”
An attempt to equalize both population and voters would have
especially bad consequences for minority representation. In a
forthcomingpaper<http://papers.ssrn.com/sol3/papers.cfm%3Fabstract_id=2631666>Vanderbilt
law and mathematics professor Paul Edelman shows that it is
mathematically possible to draw districts that equalize both voters
and population — but only at a big cost. He concludes that “dual
districting may well be antithetical to achieving majority-minority
districts,” a cornerstone of the Voting Rights Act.
It’s also impossible at this point to reliably draw districts with
an equal number of voters. As Nathaniel Persily of Stanford Law
School has argued, we simply don’t have the data to do it.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Argument analysis: Justices hard to read on Arizona redistricting
plan” <http://electionlawblog.org/?p=78168>
Posted onDecember 8, 2015 9:19 pm
<http://electionlawblog.org/?p=78168>byRick Hasen
<http://electionlawblog.org/?author=3>
Amy Howe
<http://www.scotusblog.com/2015/12/argument-analysis-justices-hard-to-read-on-arizona-redistricting-plan/>on
Harris oral argument:
“Where’s the beef?” That was the question from Washington attorney
Paul Smith, arguing at the Court today on behalf of the five-member
independent commission charged with drawing new state legislative
maps for Arizona. The Justices heard oral arguments in a challenge
by several Arizona voters to the maps that the commission drew after
the 2010 census; the voters allege that the commission violated the
principle of “one person, one vote” when it intentionally put too
many residents into Republican-leaning districts while putting too
few into Democratic-leaning districts. The Court’s four more
liberal Justices seemed inclined to agree with Smith, but some of
the Court’s more conservative Justices were harder to read. Because
a ruling in favor of the challengers could potentially affect
redistricting maps around the country, both sides could be on
tenterhooks waiting for the Court’s eventual decision.
My own read of the transcript was that Thor was really getting hung up
even with the conservatives in dealing with the lower court’s factual
finding that the Commission’s predominant motivation in deviating from
perfect equality in drawing the districts was a good faith belief it was
required by the Voting Rights Act. That, and the fact that he offered no
good standard for determining how much partisanship in districting is
too much to allow deviations from one person, one vote made me think the
challengers are likely to lose this one.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Supreme Court Landmark Case Baker v. Carr”
<http://electionlawblog.org/?p=78166>
Posted onDecember 8, 2015 9:15 pm
<http://electionlawblog.org/?p=78166>byRick Hasen
<http://electionlawblog.org/?author=3>
Well-timed
<http://www.c-span.org/video/?327719-1/supreme-court-landmark-case-baker-v-carr>C-SPAN
landmark case discussion.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Evenwel Oral Argument News Roundup <http://electionlawblog.org/?p=78164>
Posted onDecember 8, 2015 9:14 pm
<http://electionlawblog.org/?p=78164>byRick Hasen
<http://electionlawblog.org/?author=3>
NYT
<http://www.nytimes.com/2015/12/09/us/politics/supreme-court-to-hear-arguments-on-one-person-one-vote.html>
LAT
<http://www.latimes.com/nation/la-na-supreme-court-election-districts-20151208-story.html>
WSJ
<http://www.wsj.com/articles/supreme-court-to-hear-two-disputes-over-how-to-draw-political-maps-1449576004>
NPR
<http://www.npr.org/2015/12/08/458795687/when-drawing-districts-should-states-count-each-person-or-each-voter>
Buzzfeed
<http://www.buzzfeed.com/chrisgeidner/supreme-court-considers-what-one-person-one-vote-means-today?utm_term=.svAzr1GMj#.dgAxjBrD9>
USA Today
<http://www.usatoday.com/story/news/2015/12/08/supreme-court-voting-rights-texas-population-voters/76982334/>
AP
<http://hosted.ap.org/dynamic/stories/U/US_SUPREME_COURT_VOTING_RIGHTS?SITE=AP&SECTION=HOME&TEMPLATE=DEFAULT>
Reuters
<http://www.reuters.com/article/us-usa-court-election-idUSKBN0TR25A20151208>
SCOTUSBlog
<http://www.scotusblog.com/2015/12/argument-analysis-the-choice-be-bold-or-practical/>
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“What Exactly Does ‘One Person, One Vote’ Mean, Anyway? The Supreme
Court justices turn a simple question into something more
complicated.” <http://electionlawblog.org/?p=78162>
Posted onDecember 8, 2015 9:08 pm
<http://electionlawblog.org/?p=78162>byRick Hasen
<http://electionlawblog.org/?author=3>
Dahlia Lithwick
writes<http://www.slate.com/articles/news_and_politics/supreme_court_dispatches/2015/12/evenwel_v_abbott_the_supreme_court_hears_arguments_in_a_voter_apportionment.html>for
Slate.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“At the Supreme Court, Equal Representation Is in Danger”
<http://electionlawblog.org/?p=78160>
Posted onDecember 8, 2015 8:53 pm
<http://electionlawblog.org/?p=78160>byRick Hasen
<http://electionlawblog.org/?author=3>
David Gans writes
<https://newrepublic.com/article/125362/supreme-court-equal-representation-danger>for
TNR.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
WI AG: “John Doe II Must End” <http://electionlawblog.org/?p=78158>
Posted onDecember 8, 2015 8:52 pm
<http://electionlawblog.org/?p=78158>byRick Hasen
<http://electionlawblog.org/?author=3>
Statement <https://www.doj.state.wi.us/blog/john-doe-ii-should-end>:
The Wisconsin Supreme Court has issued yet another decision in John
Doe II, the protracted and secret investigation into whether a
political group exercising free political speech rights improperly
coordinated with Governor Walker during the recall election. For the
second time this year, the Wisconsin Supreme Court directed that the
John Doe proceeding be halted based upon the Court’s conclusion that
prosecutors did not have a legal basis to investigate these
political groups when they commenced John Doe II. The Court found
that campaign finance statutes upon which the prosecutors relied
violate free political speech rights guaranteed by both the United
States Constitution and the Wisconsin Constitution.
Thus, the Court said that the matter is closed, and the evidence
seized through subpoenas and search warrants issued as part of the
investigation must be returned. That has not yet occurred, and the
owners of that property are understandably upset.
The special prosecutor has indicated that he intends to appeal. The
only level of appeal left is to the Supreme Court of the United
States (SCOTUS), but it is very unlikely SCOTUS would take the case.
In the unlikely scenario that SCOTUS were to accept the case, it
would more than likely uphold the Wisconsin Supreme Court’s decision.
I write because I have indirectly been asked as Wisconsin Attorney
General to intervene on behalf of the John Doe targets. The
Wisconsin DOJ played a role in the proceedings before the Wisconsin
Supreme Court, although it was not a leading role. DOJ represented
the judge who was assigned to John Doe II after the initial judge
recused herself. The new judge quashed subpoenas issued in the John
Doe proceeding, finding that the special prosecutor’s theory of the
case was not supported by Wisconsin law. The special prosecutor
appealed that ruling, and DOJ represented the judge in the Wisconsin
Supreme Court.
Last week, the Wisconsin Supreme Court again ordered that the seized
evidence be returned to its owners. Given that DOJ represented the
judge who first found that the John Doe proceeding was invalid, DOJ
certainly has no intention of standing in the way of those orders.
The Supreme Court’s order should be carried out forthwith. DOJ has
no authority to represent those individual property owners in their
effort to enforce the Supreme Court’s order.
This has been a long, unfortunate chapter in Wisconsin’s history. The
courts have unequivocally rejected the John Doe investigation, both in
the manner in which it was carried out, as well as the legal arguments
brought by the prosecutors. The Wisconsin Supreme Court has now ordered
that the property seized be returned. For everyone involved, the special
prosecutor should end the case, and the property seized from the
individuals in this case should be returned immediately.
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Posted inchicanery <http://electionlawblog.org/?cat=12>
“Be careful what you wish for in Evenwel, Justice Kennedy”
<http://electionlawblog.org/?p=78156>
Posted onDecember 8, 2015 8:47 pm
<http://electionlawblog.org/?p=78156>byRick Hasen
<http://electionlawblog.org/?author=3>
Joey Fishkin blogs.
<http://balkin.blogspot.com/2015/12/be-careful-what-you-wish-for-in-evenwel.html>
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Six Takeaways from the Evenwel Argument
<http://electionlawblog.org/?p=78154>
Posted onDecember 8, 2015 4:07 pm
<http://electionlawblog.org/?p=78154>byRichard Pildes
<http://electionlawblog.org/?author=7>
The argument, which I attended this morning, was unusually subdued. I
think that’s because the prior case, challenging the Arizona Independent
Redistricting Commission’s plan, was tedious and frustrating to the
Court, with the lawyers challenging the Commission’s plan not able to
give the Court clear, consistent answers regarding their basic theory of
the case. The Court was energetic in the first case but then seemed a
bit worn down from the unsatisyfing first argument. But in terms of
how/Evenwel/is likely to come out, here are my views on six central points:
1. The Court is not going to hold that voter equality (equal numbers
of eligible voters per district) is constitutionally required.
Justice Kennedy showed no interest in that position and asked no
questions that suggested he was wrestling with embracing that view.
That is consistent with my view going into the case that it was
always unlikely this Court would conclude that voter equality is
required. Some early journalistic coverage of the argument, such
ashere,
<http://www.latimes.com/nation/la-na-supreme-court-election-districts-20151208-story.html>portray
the Court as likely to adopt the voter equality standard, but I
think those stories misunderstand the nature of the questions
Justice Kennedy was asking.
2. The Court is not going to embrace the other clean, polar position
either, which is that the Constitution requires that total
population be the measure. That issue was not properly teed up for
the Court, with none of the counsel before the Court arguing that
the Court should adopt total population. The issue here is whether
the Court will expressly leave this question open and keep alive the
possibility that, if and when the Court has to confront that
question, the Court would then clearly be free to decide that total
population is the required standard.
3. So the Court will either affirm the status quo or adopt an
intermediate position to which Justice Kennedy appears drawn. That
is the view that states have to at least/consider/voter equality
as/one factor/to take into account. He consistently returned to
this question and it seemed his central instinct about the case.
Texas acknowledges that it did not take voter equality into account
at all (the State Constitution prohibits that) and this case was
tossed out at the very first stage of the litigation, on a motion to
dismiss. Justice Kennedy asked more than once whether, given this
context, states should have at least the/minimal/obligation to see
whether they could do a better job at diminishing inequalities among
eligible voters across districts, without perhaps sacrificing too
much other constitutional and redistricting values. If the Court
adopts this approach, that would be slicing the issues pretty thinly
between the two sides. If this view prevails, it would impose a
process-oriented obligation: voter equality is a factor that must
be “considered.”
4. This would look like a victory for the appellants, but it would be a
win on the most minimal grounds. Moreover, even that holding might
be accompanied by qualifications concerning the reliability of the
ACS data that counts citizens and non-citizens. There is a debate
among the briefs, reflected at the argument, over the reliability of
this data, and I don’t know if the Court would want to resolve that
issue for itself in the first instance. So even this narrow holding
might come in this form: states have to at least consider voter
equality, to the extent there is accurate and reliable data on that,
and we leave it to the lower courts in specific cases to address
that reliability question.
5. If the Court holds that states have to take voter equality “into
account” as “a factor,” what would that mean on the ground? The key
question would then become: how much weight do states have to give
this factor, compared to total population, once they start “taking
it into account?” The Court is not likely to answer that question
and it will likely take years of litigation to sort it out. But I
think the most the Court would ultimately hold is that if states can
do more to promote voter equality, while not allowing their
districts to vary in total population by more than 10% and while not
violating traditional districting principles, then/within those
constraints/, states would need to avoid unnecessary departures from
voter equality. That is a long way away from a requirement that
districts be based on voter equality — as a practical matter, even
if there is a majority for the position Justice Kennedy was
debating, I think the practical effect would be very modest changes
in outcomes concerning how districts are designed and how the
distribution of political power is affected.
6. The most important effect of/Evenwel/is not, therefore, likely to be
doctrinal. The case itself — as is often true of Supreme Court
cases — raises the visibility of an option that many jurisdictions
might well not have considered before. Redistricters have been
routinely using the Census data, which is total population data. In
some areas where the politics over immigration are particularly
heated, some states or local government bodies might now start
talking about shifting to CVAP data in the next redistricting
cycle. Will the litigation itself become a catalyst for some states
to choose of their own accord to start districting based on voter
equality, rather than total population — even if the Court’s
decision does nothing more than affirm the status quo, in which this
option has always been possible. That is the most politically
consequential question surrounding this case, given that the Court
is not going to hold that districting based on voter equality is
constitutionally required.
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
Clearing the Brush in Today’s One-Person, One-Vote Case
<http://electionlawblog.org/?p=78146>
Posted onDecember 8, 2015 2:22 pm
<http://electionlawblog.org/?p=78146>bynpersily
<http://electionlawblog.org/?author=8>
The oral argument today in/Evenwel v. Abbott/was revealing in many
respects, as such arguments often are, in highlighting which points in
the briefs command the most attention from the Justices. However, as is
also often the case, the oral argument can serve to obscure certain
points, as advocates attempt to use their time to complicate issues that
really are quite simple. Such is the case, I believe, with the debate
in/Evenwel/over whether redistricting on some basis other than total
population is possible. On this question, I should note I am hardly a
disinterested observer, having filed anamicus brief
<http://electionlawblog.org/wp-content/uploads/evenwel-persily-Brief.pdf>based
on my experience as a Special Master and court-appointed redistricting
expert, and having written about the issue inPolitico
<http://www.politico.com/magazine/story/2015/06/the-supreme-courts-big-data-problem-118568>,Scotusblog
<http://www.scotusblog.com/2015/08/symposium-evenwel-v-abbott-and-the-constitutions-big-data-problem/>,
and theWashington Post
<https://www.washingtonpost.com/news/in-theory/wp/2015/10/19/theres-nothing-conservative-about-destabilizing-our-election-system/>.
To be clear, the issue is not whether one is physically able to draw
districts on the basis on some data source other than the census
population numbers. Of course, one could. The question is whether the
available data are consistent with the theory of one person, one vote –
even according to the Appellants’ novel interpretation of that rule.
There is a fundamental incongruity between the interpretation of the
Equal Protection Clause proposed by the Appellants and the data they use
to demonstrate a constitutional violation and suggest as a remedy.
First, no dataset of eligible voters exists. All of the debate about
the American Community Survey’s (ACS) citizen voting age population
(CVAP) data is somewhat beside the point. Even that dataset does not
pretend to capture the relevant statistic — eligible voters — that the
Appellants contend is necessary for compliance with one person, one
vote. The ACS data do not account for 168,000 people in Texas prisons
or the roughly 350,000 others who are disfranchised because of a felony
conviction. Nor do they account for the roughly half million eligible
voters who live abroad but can vote in Texas elections. These large
categories of persons do not amount to rounding errors or statistical
nit-picks – even if the ACS were accurate, it does not satisfy
Appellants own constitutional standard for one person, one vote compliance.
Second, the problem with the ACS CVAP data is not that you are unable to
put it into a computer and use it for redistricting. You could do that
with any dataset. Rather, what you would be putting into the computer
at the time of redistricting are old estimates of what the population
was, not what it is. Everyone, including Appellants, agrees that the
yearly ACS surveys are not usable for redistricting because they only
sample 2.5% of households and are released only for communities in
excess of 65,000 people. Therefore, they say, you should use the
averages of the ACS surveys from the previous five years – that is, use
five-year old data to redistrict for a ten-year redistricting cycle! At
the time of the 2011 redistricting, for example, you would have had to
use data averaged from the 2006 to 2010 surveys. Some of the 17 year
olds not counted in the 2006 CVAP numbers, for example, would be 23
years old by the time of the first elections held under the new lines.
Third, the granularity of the data and the presence of error margins
introduce novel questions regarding one person, one vote. Again, the
point here is not whether one is/able/to redistrict on the basis of
survey results: You could draw lines to equalize between districts the
number of Donald Trump supporters according to presidential preference
surveys. Rather, the idea of a survey – as compared to a census – is in
tension with the notion of one-person, one-vote. The linedrawer who
draws a district using the ACS survey data is, in effect, saying that he
or she is 90 percent certain (the ACS’s reported confidence intervals)
that the population in that district is within the margin of error as
reported by the survey. As explained in myamicus brief
<http://electionlawblog.org/wp-content/uploads/evenwel-persily-Brief.pdf>,
these error margins are sometimes quite large, especially at the local
level. Such errors will increase further in size, if one needs to break
up the block groups into blocks, as one often would do, in order to
accommodate any number of other redistricting considerations. (Even the
five-year averages of ACS data are not released below the block group
level.) When it comes to ACS citizenship data, moreover, some of the
data are imputed by the Census Bureau, itself: For five percent of
respondents in the 2013 ACS, the Bureau “allocated” (i.e., filled in)
the answer to the citizenship question.
Finally, and perhaps most obviously, the ACS can be eliminated at any
time. This is not a theoretical possibility: the House of
Representatives voted to eliminate it in 2012. Further, because of the
government shutdown in 2013 and a reduction in funding in 2004, ACS
surveys in those years suffered from a high margin of error.
I hope the ACS stays around, as it is an invaluable tool to inform
public policy, including the redistricting process. But the possibility
that it might disappear highlights the irony in the/Evenwel/Appellants’
argument. They maintain that the only constitutionally required
population dataset – namely, the census enumeration of persons – is
actually forbidden by the Constitution for use in redistricting. That
just cannot be right.
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
Evewel and Harris Transcripts Now Available
<http://electionlawblog.org/?p=78142>
Posted onDecember 8, 2015 10:59 am
<http://electionlawblog.org/?p=78142>byRick Hasen
<http://electionlawblog.org/?author=3>
Tuesday, December 08
14-232 <http://www.supremecourt.gov/qp/14-00232qp.pdf> Harris v.
Arizona Independent Redistricting Comm’n Transcript
<http://www.supremecourt.gov/oral_arguments/argument_transcripts/14-232_c0ne.pdf>
14-940 <http://www.supremecourt.gov/qp/14-00940qp.pdf> Evenwel v.
Abbott Transcript
<http://www.supremecourt.gov/oral_arguments/argument_transcripts/14-940_c07e.pdf>
I’m off to a long meeting and to give a talk, so commentary from me
about these tonight or tomorrow.
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
--
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
rhasen at law.uci.edu
http://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org
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