Facts
- After the 2010 census, West Virginia enacted a 2011 congressional redistricting statute for its three U.S. House districts.
- The plan produced small, nonzero population deviations among districts (overall range under 1%).
- In drawing the map, the legislature sought to (1) avoid placing two incumbents in the same district, (2) keep counties and political subdivisions intact (no county splits), and (3) preserve the cores of prior districts.
- A county commission and individual voters challenged the plan, arguing that alternative maps could have reduced the population deviations further.
- A three-judge federal district court held the statute unconstitutional under Article I, § 2, declared it invalid, and enjoined its implementation.
- State officials appealed directly to the Supreme Court, which stayed the injunction and decided the case per curiam without oral argument.
Issues
- Whether a congressional redistricting plan with small but nonzero population deviations violates Article I, § 2 when more population-equal alternatives are available.
- Whether the State satisfied its burden to justify each significant population variance as necessary to achieve legitimate, consistently applied state objectives.
Decision
- The Supreme Court reversed and remanded.
- The Court held that the challengers’ showing of more population-equal alternatives did not end the inquiry.
- The Court concluded West Virginia carried its burden to justify the deviations as necessary to achieve legitimate, consistently applied objectives, including avoiding incumbent pairings, preserving county boundaries, and maintaining existing district cores.
- The Court found the district court misapplied the governing standard and failed to give proper deference to the State’s reasonable political judgments in selecting among map options.
Legal Principles
- Article I, § 2 requires congressional districts to be drawn with populations “as nearly as is practicable” equal, but the analysis follows the burden-shifting framework of Karcher v. Daggett.
- First, plaintiffs must show that population differences could have been reduced or eliminated by a good-faith effort to draw equal-population districts.
- If plaintiffs meet that showing, the State must prove each significant variance was necessary to achieve a legitimate, consistently applied state objective.
- The existence of a more mathematically equal alternative does not automatically invalidate a plan if the State demonstrates that its legitimate objectives would be materially impaired by adopting the alternative.
- Federal courts must accord appropriate deference to a State’s reasonable choices among competing redistricting criteria when evaluating small, justified deviations.
Conclusion
The Court upheld West Virginia’s congressional plan, ruling that small population deviations do not violate Article I, § 2 when the State proves the deviations were necessary to accomplish legitimate, consistently applied redistricting goals, and that lower-deviation alternatives would compromise those goals.