Subject: Re: Colorado Redistricting Decision
From: mleen@law.harvard.edu
Date: 12/5/2003, 11:36 AM
To: Steven Mulroy
CC: Michael McDonald <mmcdon@gmu.edu>, election-law <election-law@majordomo.lls.edu>

The federal constitution may limit the extent to which the state constitution 
can limit the power of the state legislature.  Additionally, if the Supreme 
Court believes that the Colorado court's interpretation of state law is based 
on an erroneous view of federal law it might reverse and remand with 
instructions of the federal law (The Supreme Court did this type of thing in a 
death penalty case in Georgia, I believe, a while back).

Mark Leen
HLS 3L
Quoting Steven Mulroy <sjmulr@wm.edu>:

How can the Republicans appeal to the Supreme Court if the Colorado Sup Ct 
decided the case based on the Colorado Constitution?  Is there a federal 
issue lurking here?

At 09:51 AM 12/05/2003 -0600, Michael McDonald wrote:
I've been traveling for my testimony in the Arizona redistricting trial, 
so I don't know if this has been posted.  The Colorado Supreme Court, 
ruling along partisan lines, ruled that more than once a decade 
redistricting in Colorado is unconstitutional.  Republicans intend to 
appeal to the U.S. Supreme Court.

Here is a link to the decision: 
<http://www.cobar.org/opinions/opinion.cfm?
OpinionID=3975>http://www.cobar.org/opinions/opinion.cfm?OpinionID=3975

An important quote from the decicion, and a guideline for the Plaiuntiffs 
in the Texas lawsuit, is below.  The state Supreme Court relied on two 
provisions in the Colorado constitution.  One was that the constitution 
did not explicitly place the power of redistricting into the state 
legislature, and that the constituion requires redistricting in as close 
proximity to the census as possible.  Thus, the legislature forfit its 
authority when it failed to produce a map in 2001, and there is nothing 
restricting the courts from taking over that authority.  Perhaps someone 
like Sam Hirsch can provide a comment on the similarity to the Texas law:

"In this opinion, we conclude that the General Assembly does not have the 
unprecedented power it claims. Federal law grants the states the authority 
to redistrict, and federal law defines and limits this power. Our state 
constitution cannot change these federal requirements. Instead, it can 
only place additional restrictions on the redistricting process. 
Therefore, even though the first sentence of Article V, Section 44, of our 
constitution appears to grant redistricting power to the state "general 
assembly" acting alone, this language has been interpreted broadly to 
include the Governor s power to approve or disapprove the legislature s 
redistricting plan, and the voters power to redistrict by initiative or by 
resort to the courts if the legislature fails to timely act. Finally, the 
second sentence of Article V, Section 44, of the Colorado Constitution 
says "when" Colorado may redistrict. The plain language of this 
constitutional provision not only requires redistricting after a federal 
census and before the ensuing general election, but also restricts the 
legislature from redistricting at any other time.

In short, the state constitution limits redistricting to once per census, 
and nothing in state or federal law negates this limitation. Having failed 
to redistrict when it should have, the General Assembly has lost its 
chance to redistrict until after the 2010 federal census."
Below is an article from the Dec. 2 Denver Post:

HEADLINE: Court tosses GOP remapping State justices overturn '03 redrawing 
of Colorado's congressional districts

The Colorado Supreme Court on Monday ruled that last spring's  redrawing 
of congressional districts was unconstitutional and  ordered next year's 
elections held using the 2002 boundaries.

In a 5-2 decision with the court's Democratic majority sticking  together, 
the state's highest court threw out the congressional  boundaries pushed 
through by Republicans last spring.

The opinion marked the first time a court had ruled directly on 
a  legislature's authority to replace a plan drawn by a state court,  said 
Tim Storey, analyst with the National Conference of State  Legislatures.

National observers said the ruling could slow a national push to  increase 
Republican power in Congress, but it remains to be seen  whether Democrats 
can capitalize on the victory.

Republicans immediately threatened to appeal the ruling to the 
U.S.  Supreme Court.

In the decision, closely watched nationwide, the Colorado Supreme  Court 
declared that redistricting can occur only once every 10  years during a 
limited window of opportunity - after a federal  census and before the 
next general election - and at no other  time.

'Having failed to redistrict when it should have, the General  Assembly 
has lost its chance to redistrict until after the 2010  federal census,' 
Chief Justice Mary Mullarkey said in the 63-page  ruling, writing for the 
majority.

The ruling came more than six months after the  Republican-controlled 
legislature hastily passed a new  congressional district map that favored 
GOP candidates in five of  Colorado's seven congressional districts, 
tossing out a 2002  court-ordered plan.

State Attorney General Ken Salazar sued the state to overturn the  new 
law, the first time since 1905 that the top law enforcement  official had 
taken such action.

The chairman of the Colorado Republican Party criticized 
Monday's  decision and called an appeal 'very likely.'

'The finding of the Colorado Supreme Court in my opinion was a  clear 
usurpation of the legislative powers of the General Assembly  as mandated 
in the Colorado Constitution,' chairman Ted Halaby  said.

'If we appeal, the question still arises as to which plan - 
the  court-ordered plan or the legislatively enacted plan - the 
2004  election will be held under,' he said.

But Salazar urged Republicans to accept the ruling.

'I think it would be a waste of resources to continue this  litigation to 
the United States Supreme Court,' Salazar said,  noting that the ruling 
was based on the Colorado Constitution.

'For the other party to decide to pursue this to the U.S. Supreme  Court 
would be a mistake. If they want to pursue it, we'll pursue  it as well. 
However, I hope that's not necessary,' Salazar said.

Democrats hope Monday's ruling will give them a better chance to  increase 
their numbers in Congress next year. Republicans now hold  five of 
Colorado's seven congressional seats.

U.S. Rep. Mark Udall, D-Colo., who participated as a plaintiff 
with  Salazar, said the GOP-drawn map actually made his 2nd 
Congressional  District politically safer for his re-election. But he said 
he  prefers competitive districts to safe districts.

'I see frankly in the U.S. House of Representatives too many safe  seats 
both Democrat and Republican seats. I think that leads to  rhetorical 
excess and ideological positions. I think we're better  served with a 
large percentage of competitive seats,' Udall said.

He declined to say if he would leave his congressional seat and  challenge 
U.S. Sen. Ben Nighthorse Campbell, a Republican, as many  Democrats have 
asked him to do. Udall said he would announce his  decision before the end 
of the year.

Nationally, Republicans have a 12-seat edge in the 435-member House  of 
Representatives.

Since Monday's court ruling was based on state law, several lawyers  who 
read the opinion said an appeal to a federal jurisdiction or  the U.S. 
Supreme Court would be more difficult.

But the ruling also dealt with the broad policy issue of how often  to 
redistrict and the stability of representation by 
congressional  representatives. Several observers predicted the ruling 
would be  looked to by other states, including Texas, where a 
similar  redistricting case is now before the courts.

'It has limited precedential value, but it does have symbolic 
and  learning value, and it certainly will be scrutinized by 
other  states,' said Storey. 'Where it could be of value is 
preventing  other states from wading into this process.'

In the dissenting opinion, Justice Rebecca Love Kourlis 
said  redistricting is the responsibility of the General Assembly 
and  that 'no specific time limits' should apply.

Republican Gov. Bill Owens agreed with Kourlis. 'This represents a  clear 
expansion of judicial authority,' said Owens, who quickly  signed the new 
map into law last spring. 'Remember, the judges are  the only unelected 
part of the three branches of government. I'm  troubled by the aggressive 
expansion of power of the unelected  judiciary.'

Supreme Court justices, like other judges, do periodically stand  for 
retention votes.

All seven justices concurred that Salazar not only had the power 
to  challenge the law before the high court, contrary to what  Republicans 
claimed, but has the ethical duty to bring an action  whenever the 
legislature passes a law that might be  unconstitutional.

'Consistent with his ethical duties and his oath of office, if 
the  attorney general has grave doubts about the constitutionality of  the 
impending 2004 general election, he must seek to resolve these  doubts as 
soon as possible,' the court said.

Salazar, a Democrat, sued the Republican secretary of state in May  after 
the law was passed in the final three days of the  legislature.

The new law pre-empted the 2002 court-approved plan under which  last 
year's general elections were held. That plan gave Republicans  an 
advantage in four districts, Democrats in two and created a  seventh 
district evenly split among Republicans, Democrats and  unaffiliated
voters.

Republican Bob Beauprez won the 7th District by 121 votes last year  but 
is expected to have an edge next year because he is an  incumbent. On 
Monday his race grew tougher as Jefferson County's  Democratic district 
attorney, Dave Thomas, announced his intention  to run.

Salazar argued that redistricting was legal only once a decade and  that 
the task had been completed by the court last year after a  divided 
legislature failed to agree on a plan in time for the  elections.

Republicans argued that the court map was temporary and that the  law 
required redistricting to be done by the legislature.

But in Monday's opinion, the court majority chastised 
the  Republican-controlled legislature for claiming they should be 
able  to redraw congressional boundaries multiple times in a single 
decade.

'Limiting redistricting to once every 10 years maximizes  stability,' the 
court said. 'a If the districts were to change at  the whim of the state 
legislature, members of Congress could  frequently find their current 
constituents voting in a different  district in subsequent elections. In 
that situation, a  congressperson would be torn between effectively 
representing the  current constituents and currying the favor of 
future  constituents.'

Democrats in Colorado and Washington, D.C., applauded the decision  and 
criticized Republicans for an abuse of power.

'The ruling is a major setback in the GOP's effort to rig the  seats of 
vulnerable Rep. Bob Beauprez in Colorado's (7th District)  and the 
Republican held open seat in Colorado's (3rd District),'  said Robert 
Matsui, chairman of the Democratic National Campaign  Committee.

'This isn't just a victory for Democrats,' said Colorado  Democratic Party 
chairman Chris Gates. 'It's a victory for all of  us in Colorado who value 
fair elections, open government and  balance of power.'

Carl Forti, spokesman for the National Republican Congressional  Committee 
in Washington, said the battle isn't over, because a  similar challenge to 
the Colorado districts is pending in federal  court in Denver.

'This was expected. It's far from over. There's still a federal  case to 
play out,' Forti said.

But David Fine, an attorney for the Democrats who filed the  separate suit 
now in federal court, said the case is over, though  he will not ask for 
an outright dismissal.

"We don't believe our case needs to go further," he said. "But  we do not 
want to waive our ability to litigate if for some reason  the U.S. Supreme 
Court overrules the state Supreme Court."