[EL] ELB News and Commentary 6/30/15
Rick Hasen
rhasen at law.uci.edu
Tue Jun 30 08:16:21 PDT 2015
AZ Redistricting Roundup <http://electionlawblog.org/?p=73912>
Posted onJune 30, 2015 8:05 am
<http://electionlawblog.org/?p=73912>byRick Hasen
<http://electionlawblog.org/?author=3>
NYT
<http://www.nytimes.com/2015/06/30/us/supreme-court-upholds-creation-of-arizona-redistricting-commission.html?hp&action=click&pgtype=Homepage&module=first-column-region®ion=top-news&WT.nav=top-news>
WaPo
<http://www.washingtonpost.com/politics/courts_law/justices-rule-5-4-that-independent-panels-can-draw-election-district-lines/2015/06/29/c91269aa-1ae6-11e5-ab92-c75ae6ab94b5_story.html>
LAT
<http://www.latimes.com/local/political/la-me-pol-california-arizona-redistricting-supreme-court-20150629-htmlstory.html> andLAT
<http://www.latimes.com/nation/la-na-supreme-court-congressional-districts-gerrymander-20150629-story.html#page=1>
Politico
<http://www.politico.com/story/2015/06/arizona-redistricting-commission-supreme-court-voting-119543.html>
MSNBC
<http://www.msnbc.com/msnbc/supreme-court-decision-arizona-redistricting>
WSJ
<http://www.wsj.com/articles/supreme-court-upholds-arizona-initiative-on-redrawing-voting-districts-1435588953>
AZ Republic
<http://www.azcentral.com/story/news/arizona/politics/2015/06/29/arizona-congressional-map-redistricting-supreme-court/29015171/>
USA Today
<http://www.usatoday.com/story/news/nation/2015/06/29/supreme-court-arizona-congress-maps/27400015/>
CNN
<http://www.cnn.com/2015/06/29/politics/supreme-court-arizona-redistricting-ruling/>
AP
<http://m.cjonline.com/news/2015-06-29/us-supreme-court-upholds-arizonas-system-redistricting#gsc.tab=0>
Bloomberg
<http://www.bloomberg.com/politics/articles/2015-06-29/independent-redistricting-panel-upheld-by-u-s-supreme-court>
Reuters
<http://www.newsweek.com/supreme-court-upholds-independent-voter-approved-commission-arizona-348099>
My Slate column on the case ishere
<http://www.slate.com/articles/news_and_politics/jurisprudence/2015/06/arizona_supreme_court_decision_redistricting_ruling_undermines_bush_v_gore.html>.
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Posted inElections Clause
<http://electionlawblog.org/?cat=70>,redistricting
<http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Gridlocked elections watchdog goes two years without top lawyer;
FEC’s inaction hamstrings enforcement process, critics say”
<http://electionlawblog.org/?p=73910>
Posted onJune 30, 2015 8:01 am
<http://electionlawblog.org/?p=73910>byRick Hasen
<http://electionlawblog.org/?author=3>
CPI reports.
<http://www.publicintegrity.org/2015/06/30/17566/gridlocked-elections-watchdog-goes-two-years-without-top-lawyer>
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,federal
election commission <http://electionlawblog.org/?cat=24>
“A Redistricting Ruling That Helps Counter Partisan Gerrymandering”
<http://electionlawblog.org/?p=73908>
Posted onJune 30, 2015 8:00 am
<http://electionlawblog.org/?p=73908>byRick Hasen
<http://electionlawblog.org/?author=3>
Linda Killian
<http://blogs.wsj.com/washwire/2015/06/29/a-redistricting-ruling-that-helps-counter-partisan-gerrymandering/>in
Wash Wire.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Will the AZ Redistricting Case Save National Popular Vote From
Constitutional Challenge? <http://electionlawblog.org/?p=73906>
Posted onJune 30, 2015 7:40 am
<http://electionlawblog.org/?p=73906>byRick Hasen
<http://electionlawblog.org/?author=3>
Yesterday’s Supreme Court decision reading the term “Legislature”
capaciously for purposes of the Elections Clause likely means it would
be read capaciously for purposes of Article II as well. This means, for
example, that if a state by initative decides to divide up its electoral
college votes proportionally rather than winner take all, or district by
district, it likely does not usurp the power of the state legislature.
(Seemy Slate
piece<http://www.slate.com/articles/news_and_politics/jurisprudence/2015/06/arizona_supreme_court_decision_redistricting_ruling_undermines_bush_v_gore.html>yesterday
on the connection of the AZ case to Bush v. Gore’s discussion of this
issue.)
But that does not mean, asRichard Winger suggests
<http://ballot-access.org/2015/06/29/todays-u-s-supreme-court-ruling-boosts-national-popular-vote-plan/>,
as easy constitutional path for the enactment of NPV, which would divide
electoral college votes of all states that agree in line with the winner
of the national popular vote.
The biggest constitutional problem with NPV is not the Legislature
question, but instead whether such an agreement among the states would
be a “compact” requiring congressional approval. Derek Muller makesa
strong argument
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=979537>that the
compact issue is a problem.
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Posted inElections Clause <http://electionlawblog.org/?cat=70>,electoral
college <http://electionlawblog.org/?cat=44>,Supreme Court
<http://electionlawblog.org/?cat=29>
“At the Supreme Court, a Win for Direct Democracy”
<http://electionlawblog.org/?p=73904>
Posted onJune 30, 2015 7:36 am
<http://electionlawblog.org/?p=73904>byRick Hasen
<http://electionlawblog.org/?author=3>
Rick Pildes
<http://www.nytimes.com/2015/06/30/opinion/at-the-supreme-court-awin-for-direct-democracy.html?action=click&pgtype=Homepage&module=opinion-c-col-right-region®ion=opinion-c-col-right-region&WT.nav=opinion-c-col-right-region&_r=0>NYT
oped concludes:
The Supreme Court often surprises critics who see it in
simplistically ideological terms. As this term and this decision
confirm, the current court remains a pragmatically minded
institution that interprets legal language with an eye toward the
problems that language was created to address. As a result, direct
democracy will remain available to constrain partisan gerrymandering
and other ways legislatures seek to manipulate democratic purposes
for self-serving reasons.
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Posted inElections Clause
<http://electionlawblog.org/?cat=70>,redistricting
<http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Ronald Keith Gaddie on AZ Redistricting
<http://electionlawblog.org/?p=73902>
Posted onJune 30, 2015 7:12 am
<http://electionlawblog.org/?p=73902>byRick Hasen
<http://electionlawblog.org/?author=3>
LSE blog
<http://blogs.lse.ac.uk/usappblog/2015/06/30/in-its-arizona-redistricting-decision-the-supreme-court-has-made-explicit-that-redistricting-initiatives-are-a-state-legislative-action/>:
One might argue that this is a conservative decision. It leaves the
status quo in place, and it defers to the state constitution in
matters of state policymaking. States are able to order their
institutions, so long as they do not deny or abridge fundamental
rights of the individual. In the case of Arizona’s proposition 106,
voters had exercised their right to enact “any law which may be
enacted by the Legislature
<http://www.azleg.gov/FormatDocument.asp?inDoc=/const/4/1.p1.htm>.”
The Court has affirmed astate right
<http://legal-dictionary.thefreedictionary.com/States%2527+Rights>.
The minority would doubtlessly disagree with this states’ rights
characterization. Justice Roberts argues that “The Court’s position
has no basis in the text, structure, or history of the Constitution,
and it contradicts precedents from both Congress and this Court.” In
effect, the Court has created this understanding of what is a
legislature anew, out of whole cloth. More specifically, he refers
to the decision as a “magic trick.” A legislature for Justice
Roberts is a republican form of legislature, the representative
institution, rather than the potentially evolving legislative
authority of the state.
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Posted inElections Clause
<http://electionlawblog.org/?cat=70>,redistricting
<http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Breaking: #SCOTUS to Hear ANOTHER AZ Redistricting Case
<http://electionlawblog.org/?p=73892>
Posted onJune 30, 2015 6:33 am
<http://electionlawblog.org/?p=73892>byRick Hasen
<http://electionlawblog.org/?author=3>
The case
<http://www.supremecourt.gov/orders/courtorders/063015zr_pnk0.pdf>is
Wesley v. AZ Redistricting Commission (14-232) and the three questions
presented (in thejurisdictional statement
<http://redistricting.lls.edu/files/AZ%20harris%2020140825%20juris.pdf>)
deal with one person, one vote deviations to satisfy partisan
advantage, deviations from partisan advantage to satisfy the (now
defunct) preclearance requirements of the DOJ, and whether the
redistricting commission erred in allegedly drawing Hispanic influence
districts. This could turn out to be a major case, although the first
question seems to have been resolved by the Supreme Court’s summary
affirmance in Larios v. Cox, and the second question seems mooted by
/Shelby County/‘s killing of preclearance. I am not sure why the Court
took this case rather than a simple summary affirmance, but we will find
out soon enough. Perhaps the Court thought it should take the case while
the larger /Evenwel/one person, one vote case was pending.
The full questions presented are:
Screen Shot 2015-06-30 at 6.38.46 AM
<http://electionlawblog.org/wp-content/uploads/Screen-Shot-2015-06-30-at-6.38.46-AM.png>
Via Justin Levitt, <http://redistricting.lls.edu/cases-AZ.php#AZ>here
are the relevant documents:
*District court*
–*_Opinion_rejecting challenges*
<http://redistricting.lls.edu/files/AZ%20harris%2020140429%20order.pdf>,_concurrence_
<http://redistricting.lls.edu/files/AZ%20harris%2020140429%20concur.pdf>,_dissent_
<http://redistricting.lls.edu/files/AZ%20harris%2020140429%20dissent.pdf>(Apr.
29, 2014).
*U.S. Supreme Court*
–Notice of appeal
<http://redistricting.lls.edu/files/AZ%20harris%2020140625%20noa.pdf>(June
25).
–Jurisdictional statement
<http://redistricting.lls.edu/files/AZ%20harris%2020140825%20juris.pdf>(Aug.
25).
–Motion to dismiss or affirm
<http://redistricting.lls.edu/files/AZ%20harris%2020141113%20affirm.pdf>(Nov.
13).
–Opposition
<http://redistricting.lls.edu/files/AZ%20harris%2020141202%20opp.pdf>(Dec.
2).
Thor Hearne, whose fraudulent fraud squad activities get full play in my
book, /The Voting Wars/, brought this case.
This post has been updated.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>,Voting Rights Act
<http://electionlawblog.org/?cat=15>
“Standing in the Arizona Redistricting Case: Some Initial
Observations” <http://electionlawblog.org/?p=73890>
Posted onJune 29, 2015 4:11 pm
<http://electionlawblog.org/?p=73890>byRick Hasen
<http://electionlawblog.org/?author=3>
My @UCILaw colleague Seth Davis with someinteresting thoughts
<http://prawfsblawg.blogs.com/prawfsblawg/2015/06/standing-in-the-arizona-redistricting-case-some-initial-observations.html>.
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Posted inSupreme Court <http://electionlawblog.org/?cat=29>
“When ‘Legislature’ May Mean More than ‘Legislature': Initiated
Electoral College Reform and the Ghost of Bush v. Gore”
<http://electionlawblog.org/?p=73888>
Posted onJune 29, 2015 4:04 pm
<http://electionlawblog.org/?p=73888>byRick Hasen
<http://electionlawblog.org/?author=3>
I wrotethis piece
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1065421>in 2008 for
the /Hastings Constitutional Law Quarterly. /After the AZ case, I can
say that I now think it is very likely that initiated electoral college
reform would satisfy the Legislature requirement of Article II. Here’s
the abstract:
This Article, forthcoming in a symposium in the Hastings
Constitutional Law Quarterly, examines the question of the
constitutionality of changes to the Electoral College accomplished
through the initiative process; it does not discuss the merits of
either the Electoral College or reforms that have been proposed to
change it (whether through the initiative process or otherwise).
Part I gives the brief history of attempts to use the state
initiative process to change the rules for choosing presidential
electors, beginning with Colorado’s Amendment 36, which would have
divided the state’s electoral votes proportionally but failed to
pass in the 2004 election, to the current California Electoral
College measure, which would divide electoral votes mostly by
congressional district and whose fate is unclear as of this writing.
It also explains that even if the California measure fails to
qualify or pass, this issue could well arise in a future election
because of general dissatisfaction among segments of the population
with the Electoral College system for choosing the President. Part
II turns to the constitutional question whether initiated changes to
rules for choosing presidential electors violate Article II. It
offers an analysis of the question based upon the text of Article
II, relevant Supreme Court caselaw involving Article II, as well as
Articles I and V, and the possible purposes behind Article II’s use
of the term Legislature. It concludes that the issue of the
constitutionality of initiated Electoral College reform is a
difficult one to resolve about which reasonable jurists will differ,
and because of that difficulty resolution by the Supreme Court could
appear to be colored by the political considerations of who could
lose or win by resolution of the question raising the specter of
another Bush v. Gore. Part III concludes with two strategies that
can help avoid the Article II question from becoming the next Bush
v. Gore. First, courts should be more willing to engage in
pre-election review of such measures, so that these issues can be
resolved before, rather than after, an election. Second, Congress
should consider amending the Constitution with an election
administration amendment that would impose a two-year waiting period
before any state’s changes to Electoral College rules may go into
effect. An amendment changing the Electoral College itself would be
difficult to pass through Congress and the states. But my proposal
is a neutral amendment ex ante that could decouple the consideration
of the merits of Electoral College reform from the short term
political advantages that could come from such a change.
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Posted inElections Clause <http://electionlawblog.org/?cat=70>,Supreme
Court <http://electionlawblog.org/?cat=29>
“The Arizona Decision: Constitutional Reasoning Within the Reform
Model” <http://electionlawblog.org/?p=73886>
Posted onJune 29, 2015 3:49 pm
<http://electionlawblog.org/?p=73886>byRick Hasen
<http://electionlawblog.org/?author=3>
Bauer
<http://www.moresoftmoneyhardlaw.com/2015/06/arizona-decision-constitutional-reasoning-within-reform-model/>:
The next few days of commentary onthe Arizona redistricting decision
<http://www.supremecourt.gov/opinions/14pdf/13-1314_kjfl.pdf>will
include the usual debate about which side had the better of the
“legal argument.” And, in truth, both the majority opinion and the
chief (Roberts) dissent can be defended. Each is effectively drawn,
making the most of the materials available to it. Each also takes
the usual liberties with the construction of precedent and the
standards by which particular points—an example being the majority’s
reliance on 2 U.S.C. §2(a)(c)—are deemed relevant. More interesting
is the way that the majority weighs the/reform/objective. The
majority in the Arizona case adheres to a model familiar in
political reform arguments more generally, within and outside the Court.
For this majority, the constitutional question cannot be considered
apart from the reform objective served by the initiative creating
the Independent Redistricting Commission. The “people” are seen to
be taking urgent steps to protect against officeholder
self-interestedness. So, as Justice Thomas points out in dissent,
the Court here lauds the exercise of direct democracy, which at
other times is given the back of its hand. The reason for the
difference is simple: the objective that the tools of direct
democracy have been in this case wielded to bring about.
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Posted inSupreme Court <http://electionlawblog.org/?cat=29>
Sam Wang on AZ Redistricting Case <http://electionlawblog.org/?p=73884>
Posted onJune 29, 2015 3:29 pm
<http://electionlawblog.org/?p=73884>byRick Hasen
<http://electionlawblog.org/?author=3>
Here
<http://election.princeton.edu/2015/06/29/scotus-upholds-arizona-redistricting-commission-5-4/>.
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Posted inSupreme Court <http://electionlawblog.org/?cat=29>
“Supreme Court Approves Arizona Redistricting Commission”
<http://electionlawblog.org/?p=73882>
Posted onJune 29, 2015 3:19 pm
<http://electionlawblog.org/?p=73882>byRick Hasen
<http://electionlawblog.org/?author=3>
Carrie Johnson reports
<http://www.npr.org/2015/06/29/418641145/supreme-court-approves-arizona-redistricting-commission>for
NPR.
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
Small Error in Justice Ginsburg’s AZ Redistricting Decision
<http://electionlawblog.org/?p=73880>
Posted onJune 29, 2015 2:33 pm
<http://electionlawblog.org/?p=73880>byRick Hasen
<http://electionlawblog.org/?author=3>
A reader via email notes to me that Justice Ginsburg’s decision in the
AZ redistricting case contains a minor error of fact on page 8 ofthe
slip opinion <http://electionlawblog.org/wp-content/uploads/az.pdf>. The
opinion states:
The California Redistricting Commission, established by popular
initiative, develops redistricting plans which become effective if
approved by public referendum.7
7. See Cal. Const., Art. XXI, §2; Cal. Govt. Code Ann. §§8251–8253.6
(West Supp. 2015).
In fact, there is no referendum requirement inArt. XXI
<http://www.leginfo.ca.gov/.const/.article_21>of the state Constitution.
Instead, the go into effect after being approved, but they are subject
to potential referendum under the usual rules for referenda of
legislative matters. See Cal. Consts. Art. XXI section 2(i):
(i) Each certified final map shall be subject to referendum in the same manner that a statute is subject to referendum pursuant to Section 9 of Article II. The date of certification of a final map to the Secretary of State shall be deemed the enactment date forpurposes of Section 9 of Article II.
The last time readerspointed out an error
<http://electionlawblog.org/?p=67193>in a Justice Ginsburg opinion, I
noted it on the blog and the Justicequickly
<http://electionlawblog.org/?p=67275>corrected it
<http://electionlawblog.org/?p=67566>.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Justices Rule for Arizona’s Independent Redistricting Commission”
<http://electionlawblog.org/?p=73878>
Posted onJune 29, 2015 2:13 pm
<http://electionlawblog.org/?p=73878>byRick Hasen
<http://electionlawblog.org/?author=3>
Mike Sacks and Marcia Coyle report <http://t.co/vfTGj6IzMy>for the NLJ.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Will Kansas Have Two Election Registration Systems, One for Federal
and One for State? <http://electionlawblog.org/?p=73876>
Posted onJune 29, 2015 1:42 pm
<http://electionlawblog.org/?p=73876>byRick Hasen
<http://electionlawblog.org/?author=3>
Challenge pending
<http://www2.ljworld.com/news/2015/jun/29/high-court-wont-review-kansas-proof-citizenship-ru/>,
now ripe after cert denial inKobach v. EAC
<http://electionlawblog.org/?p=73829>.
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Posted inelection administration
<http://electionlawblog.org/?cat=18>,NVRA (motor voter)
<http://electionlawblog.org/?cat=33>,The Voting Wars
<http://electionlawblog.org/?cat=60>
“Hillary Clinton Faces a More Liberal Democratic Fund-Raising
Landscape” <http://electionlawblog.org/?p=73874>
Posted onJune 29, 2015 1:36 pm
<http://electionlawblog.org/?p=73874>byRick Hasen
<http://electionlawblog.org/?author=3>
Important
<http://www.nytimes.com/2015/06/30/us/politics/hillary-clinton-faces-a-more-liberal-democratic-fund-raising-landscape.html>NYT
analysis:
Hillary Rodham Clinton
<http://www.nytimes.com/interactive/2015/04/13/us/elections/hillary-clinton.html?inline=nyt-per>will
seek out donors to her presidential campaign from a Democratic
fund-raising landscape vastly altered since her first presidential
bid and far more ideologically aligned with the party’s liberal
activists.
Democrats now get far less money from Wall Street, military
contractors, health care companies and other industries that for
decades ladled out cash more evenly to both parties, according to a
New York Times analysis of data collected by the Center for
Responsive Politics, a watchdog group. And the party now relies far
more on constituencies that have achieved new clout in the era of
“super PACs
<http://topics.nytimes.com/top/reference/timestopics/subjects/c/campaign_finance/index.html?inline=nyt-classifier>”
and carefully targeted digital fund-raising.
As many as one-fifth of elite Democratic “bundlers” — volunteers who
raise money from friends and business associates — are active in
gay-rights causes or are themselves gay or lesbian. Outside
Democratic groups rely heavily on wealthy environmentalists, such as
the billionaires Tom Steyer and Michael R. Bloomberg, and on labor
unions, whose financial might has been magnified by the Supreme
Court’s Citizens United decision in 2010 even as their membership
rolls decline.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,campaigns
<http://electionlawblog.org/?cat=59>
On “To the Point” Talking #SCOTUS Term
<http://electionlawblog.org/?p=73872>
Posted onJune 29, 2015 1:27 pm
<http://electionlawblog.org/?p=73872>byRick Hasen
<http://electionlawblog.org/?author=3>
I was on talking to Warren Olney with Josh Gerstein, Ilya Shapiro, and
Nan Hunter.
Listen
<http://www.kcrw.com/news-culture/shows/to-the-point/justice-kennedy-leads-the-supreme-court-towards-a-historic-term/>.
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Posted inSupreme Court <http://electionlawblog.org/?cat=29>
“Voting-Rights Advocates Get Win at Supreme Court”
<http://electionlawblog.org/?p=73870>
Posted onJune 29, 2015 1:26 pm
<http://electionlawblog.org/?p=73870>byRick Hasen
<http://electionlawblog.org/?author=3>
Roll Call reports.
<http://atr.rollcall.com/supreme-court-victory-for-voting-rights-advocates/>
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
Nate Persily on AZ Redistricting Decision, Etc.
<http://electionlawblog.org/?p=73868>
Posted onJune 29, 2015 1:02 pm
<http://electionlawblog.org/?p=73868>byRick Hasen
<http://electionlawblog.org/?author=3>
Nate, whose work was cited multiple times in today’s decision,writes
<http://stanfordlawyer.law.stanford.edu/2015/06/arizona-state-legislature-v-arizona-redistricting-committee-no-appetite-for-destruction/>:
While observers of the Court will read into these opinions – as they
should — larger principles of legislative deference or fundamental
rights or respect for the democratic process, we should not ignore
the opinions’ pragmatic side. Indeed, the Court broke new ground
with these opinions, but it also dodged several bullets. Avoiding
dramatic instability in the law, while rarely a rallying cry, is an
achievement nonetheless.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
Breaking: #SCOTUS Stays TX Abortion Order, Making Abortion Case Next
Term Very Likely: It’s Still Justice Kennedy’s Court
<http://electionlawblog.org/?p=73864>
Posted onJune 29, 2015 12:45 pm
<http://electionlawblog.org/?p=73864>byRick Hasen
<http://electionlawblog.org/?author=3>
Here
<http://www.supremecourt.gov/orders/courtorders/062915zr_6j37.pdf>is the
order:
The application for stay presented to Justice Scalia and by him
referred to the Court is granted, and the issuance of the mandate of
the United States Court of Appeals for the Fifth Circuit in case No.
14-50928 is stayed pending the timely filing and disposition of a
petition for a writ of certiorari. Should the petition for a writ of
certiorari be denied, this stay shall terminate automatically. In
the event the petition for a writ of certiorari is granted, the stay
shall terminate upon the issuance of the judgment of this Court. The
Chief Justice, Justice Scalia, Justice Thomas, and Justice Alito
would deny the application.
It is Justice Kennedy’s Court after all.
It will take only 4 Justices to hear the case, but I can’t imagine
anything but a cert. grant in this case (or the Mississippi case with
this one held). And a stay looks at a sneak peek on the merits, and
that means that the challengers have a decent likelihood of succeeding.
[This post has been updated.]
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Posted inSupreme Court <http://electionlawblog.org/?cat=29>
--
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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