[EL] Breaking: #SCOTUS to Hear ANOTHER AZ Redistricting Case

Rick Hasen rhasen at law.uci.edu
Tue Jun 30 10:58:40 PDT 2015


Now that I've read through the materials, I'm convinced they took this 
case primarily because it came from a 3 judge court, and Alito and other 
Justices were not ready to summarily affirm without giving these issues 
a fuller airing.

I don't expect this to be a blockbuster case on any count (watch me eat 
my words in a year).


On 6/30/15 10:50 AM, Justin Levitt wrote:
> /Evenwel/ will consider the nature of the population base, yes.  But 
> whatever that qualitative decision, it's hard for me to believe that 
> this Court has an interest in requiring _stricter_ adherence to 
> mathematical equality in a way that overrides other legitimate state 
> interests.  (Part of the question in the new Arizona case is an 
> allegation that the interests supporting unequal population were not 
> legitimate.)  People keep forgetting about the West Virginia case from 
> this cycle -- /Tennant/ <http://redistricting.lls.edu/cases.php#WV> -- 
> which opened up the "essentially identical" standard for congressional 
> districts to give _more_ flexibility to depart from mathematical 
> equality.  That decision was 9-0.
>
> Justin Levitt
> -- 
> Justin Levitt
> Professor of Law
> Loyola Law School | Los Angeles
> 919 Albany St.
> Los Angeles, CA  90015
> 213-736-7417
> justin.levitt at lls.edu
> ssrn.com/author=698321
> On 6/30/2015 10:22 AM, Derek Muller wrote:
>> I think all of these comments are right, but at its heart, this case, 
>> like /Evenwel/, turns on strengthening another undertheorized element 
>> of the "one person, one vote" mantra: if (essentially) identical 
>> numbers of people are require under congressional redistricting, but 
>> a 10% deviation is permitted for state legislative districts, a 
>> stronger "one person, one vote" theory would require something closer 
>> to an equal number of people in each district for state legislative 
>> districts, too. So while the districts might survive under Section 2, 
>> they might fail if the Equal Protection Clause were construed to 
>> require close(r) to equal numbers of people (or, in conjunction with 
>> /Evenwel/, equal numbers of "voters," however defined). While 
>> /Evenwel/ is different in kind, it, too, turns on a stronger 
>> interpretation of the "one person, one vote" doctrine.
>>
>> Also, I recall at oral argument in /Alabama Legislative Black Caucus 
>> /that Alabama claimed it was trying to reach equal numbers of people 
>> in its legislative districts with 2% deviations, and Justice Kagan 
>> pressing back that it wasn't required because deviations of up to 10% 
>> were permitted. A new, more stringent "one person, one vote" analysis 
>> would have a significant impact on cases like these.
>>
>> Of course, this would also join /Evenwel /as another "one person, one 
>> vote" case where (some) conservative and liberal partisans would 
>> appear to reverse their roles in, perhaps, a more results-oriented 
>> jurisprudence (see Noah Feldman's piece here: 
>> http://www.bloombergview.com/articles/2015-05-27/-one-man-one-vote-keeps-changing)....
>>
>> Derek
>>
>> Derek T. Muller
>>
>> Associate Professor of Law
>>
>> Pepperdine University School of Law
>>
>> 24255 Pacific Coast Hwy
>>
>> Malibu, CA 90263
>>
>> +1 310-506-7058
>>
>> SSRN: http://papers.ssrn.com/author=464341
>>
>> Twitter: http://twitter.com/derektmuller
>>
>> On Tue, Jun 30, 2015 at 9:48 AM, Gaddie, Ronald K. <rkgaddie at ou.edu> 
>> wrote:
>>
>>     I think the S.5 argument can fall apart because all those
>>     districts could be justified via S.2.
>>
>>     ------------------------------------------------------------------------
>>     Ronald Keith Gaddie, Ph.D.
>>     /President's Associates Presidential Professor//
>>     /Chair, Department of Political Science <http://psc.ou.edu>
>>     Associate Director, Center for Intelligence & National Security
>>     <http://cins.ouhsc.edu>
>>     The University of Oklahoma
>>     *p:* 405.325.2061 <tel:405.325.2061>**| ***e*: rkgaddie at ou.edu**|
>>     t*: *@GaddieWindage <https://twitter.com/gaddiewindage>
>>     ------------------------------------------------------------------------
>>     *From:* Rick Hasen [rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>]
>>     *Sent:* Tuesday, June 30, 2015 11:45 AM
>>     *To:* Gaddie, Ronald K.; law-election at UCI.edu
>>     *Subject:* Re: [EL] Breaking: #SCOTUS to Hear ANOTHER AZ
>>     Redistricting Case
>>
>>     I agree.  I'm reading through the materials now.
>>     It is a very messy case with three opinions from the three judge
>>     court, and the problem of relying upon a preclearance regime
>>     which is now dead.
>>
>>
>>     On 6/30/15 9:35 AM, Gaddie, Ronald K. wrote:
>>>     This appears to be a bit different from Ewel. It looks almost
>>>     like a /Larios/ challenge.
>>>
>>>     ------------------------------------------------------------------------
>>>     Ronald Keith Gaddie, Ph.D.
>>>     /President's Associates Presidential Professor//
>>>     /Chair, Department of Political Science <http://psc.ou.edu>
>>>     Associate Director, Center for Intelligence & National Security
>>>     <http://cins.ouhsc.edu>
>>>     The University of Oklahoma
>>>     *p:* 405.325.2061 <tel:405.325.2061>**| ***e*:
>>>     rkgaddie at ou.edu**| t*: *@GaddieWindage
>>>     <https://twitter.com/gaddiewindage>
>>>     ------------------------------------------------------------------------
>>>     *From:* law-election-bounces at department-lists.uci.edu
>>>     <mailto:law-election-bounces at department-lists.uci.edu>
>>>     [law-election-bounces at department-lists.uci.edu] on behalf of
>>>     Rick Hasen [rhasen at law.uci.edu]
>>>     *Sent:* Tuesday, June 30, 2015 8:47 AM
>>>     *To:* law-election at UCI.edu <mailto:law-election at UCI.edu>
>>>     *Subject:* [EL] Breaking: #SCOTUS to Hear ANOTHER AZ
>>>     Redistricting Case
>>>
>>>
>>>         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, 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.
>>>
>>>     Share
>>>     <https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D73892&title=Breaking%3A%20%23SCOTUS%20to%20Hear%20ANOTHER%20AZ%20Redistricting%20Case&description=>
>>>     Posted inredistricting
>>>     <http://electionlawblog.org/?cat=6>,Supreme Court
>>>     <http://electionlawblog.org/?cat=29>,Voting Rights Act
>>>     <http://electionlawblog.org/?cat=15>
>>>     -- 
>>>     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  <tel:949.824.3072>  - office
>>>     949.824.0495  <tel:949.824.0495>  - fax
>>>     rhasen at law.uci.edu  <mailto:rhasen at law.uci.edu>
>>>     http://www.law.uci.edu/faculty/full-time/hasen/
>>>     http://electionlawblog.org
>>
>>     -- 
>>     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  <tel:949.824.3072>  - office
>>     949.824.0495  <tel:949.824.0495>  - fax
>>     rhasen at law.uci.edu  <mailto:rhasen at law.uci.edu>
>>     http://www.law.uci.edu/faculty/full-time/hasen/
>>     http://electionlawblog.org
>>
>>
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-- 
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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