[EL] Analysis: Supreme Court Looks to Endanger Citizen Redistricting Commissions and MORE

Rick Hasen rhasen at law.uci.edu
Mon Mar 2 11:43:20 PST 2015


I read Kennedy as much more skeptical than you do.  Especially in 
relation to his 17th amendment point.

On 3/2/15 11:40 AM, Marty Lederman wrote:
> No need for alarm just yet, Rick.  Yes, I think there are almost 
> certainly four votes against Arizona on the constitutional question.  
> But Kennedy was very careful this morning not to tip his hand on where 
> he stands--he plainly has concerns with the views being offered by 
> both sides.
>
> Moreover, although none of the Justices appeared to be very interested 
> in the standing and statutory arguments (except for the Chief and 
> Alito, who were deeply skeptical), the Court itself asked the parties 
> to address them, and they certainly offer a way out -- and a way to 
> uphold the commission -- if the Justices don't wish to resolve the 
> constitutional question.  FWIW, I agree with Justice Breyer that 
> Smiley and Hildebrandt do not much help /either /side on the 
> constitutional question, except that they foreclose the idea that 
> "legislature" has precisely the same meaning wherever it appears in 
> the Constitution.  On the other hand, I think /Hildebrandt /is very 
> strong support for the statutory argument, if the Justices are 
> inclined to go that route.
>
> On Mon, Mar 2, 2015 at 2:18 PM, Rick Hasen <rhasen at law.uci.edu 
> <mailto:rhasen at law.uci.edu>> wrote:
>
>
>         Analysis: Supreme Court Looks to Endanger Citizen
>         Redistricting Commissions and MORE
>         <http://electionlawblog.org/?p=70645>
>
>     Posted onMarch 2, 2015 10:41 am
>     <http://electionlawblog.org/?p=70645>byRick Hasen
>     <http://electionlawblog.org/?author=3>
>
>     I have now had a chance to review the transcript
>     <http://electionlawblog.org/wp-content/uploads/arizona-transcript.pdf> in
>     Arizona State Legislature v. Arizona Independent Redistricting
>     Commission and the news is not good. It appears that the
>     conservative Justices may be ready to hold that citizen
>     redistricting commissions which have no role for state
>     legislatures in drawing congressional districts are
>     unconstitutional. What’s worse, such a ruling would endanger other
>     election laws passed by voter initiative trying to regulate
>     congressional elections, such as open primaries. For those who
>     don’t like campaign finance laws because they could protect
>     incumbents, this is a ruling that could make incumbency protection
>     all the worse, removing the cruciallegislative bypass
>     <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1348131>which
>     is the initiative process (for congressional elections).
>
>     The question in the case arises from the Constitution’s Elections
>     Clause, giving each state “legislature” the power to set the rules
>     for Congressional elections if Congress does not act. The key
>     question is whether the people, acting through a state’s
>     initiative process as lawmakers, are acting as the legislature for
>     purpose of this clause. If not, redistricting done without the
>     involvement of the legislature would be unconstitutional. (Before
>     the Court agreed to take the case, itseemed settled
>     <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1065421>that
>     Legislature could include the initiative process of a state.)
>
>     From my read of the transcript, Chief Justice Roberts, Justice
>     Scalia, Justice Alito, and Justice Kennedy all seemed skeptical
>     that the word “legislature” used in the Elections Clause could
>     refer to an initiated redistricting process in which the
>     legislature is not involved. Part of this turns on what
>     Legislature meant at the time of the Constitution’s drafting, as
>     well as the use of the term Legislature in other parts of the
>     Constitution which seems to more clearly refer to the
>     representative body. Of course, there was no regular initiative
>     process at the time of the founding, but that fact can cut either
>     way.  There are also two precedents which seemed to support the
>     broader reading of “legislature,” but not only the conservatives,
>     but also Justice Breyer, did not believe those cases settled the case.
>
>     When you add in Justice Thomas, who is likely to join fellow
>     conservatives in reading Legislature in the narrow textual way,
>     and possibly Justice Breyer, that looks like a majority which will
>     reject a redistricting commission in which the state has no
>     involvement.
>
>     What’s worse, Justice Scalia and others suggested that Congress
>     (which has primary power over congressional elections) could not
>     simply authorize redistricting commissions for drawing districts,
>     because doing so would be an end run around the alternative power
>     given to state legislatures.
>
>     And if the Court opens this pandora’s box, it is not clear how far
>     it goes.  Can legislatures be partially involved in the process?
>     What if there is a veto power for either the legislature or a
>     commission over alternative plans.  And how far would this stop
>     other laws affecting congressional elections passed by
>     initiative?  Justice Kagan asked:
>
>         Well, Mr. Clement, well how about that, because I thought that
>         the legislature was completely cut out as to most of those
>         things. I mean, you take the 2011 law in Mississippi adopting
>         voter ID requirements; 2007, Oregon, vote by mal; 1962,
>         Arkansas, use of voting machines. All of things, these things
>         were done by referendum or by initative with the legislative
>         process completely cut out. So would all of those be
>         unconstitutional as well? And we can go further. Im ean, there
>         are zillions of these laws.
>
>     The worst part is that the initiative process is the best way to
>     deal with legislative self-interest in the political process. And
>     the Court seems poised to take away the one tool to keep down
>     partisan gerrymandering, to keep the legislature honest, and to
>     make sure the current process protects the will of the people.
>
>     What a shame.
>
>     [This post has been edited.]
>
>     Share
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>     Posted incitizen commissions
>     <http://electionlawblog.org/?cat=7>,Elections Clause
>     <http://electionlawblog.org/?cat=70>,redistricting
>     <http://electionlawblog.org/?cat=6>,Supreme 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  <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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