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Common Cause v. Rucho

Citation: 284 F. Supp. 3d 780Docket: No. 1:16–CV–1026; No. 1:16–CV–1164

Court: District Court, M.D. North Carolina; January 15, 2018; Federal District Court

Narrative Opinion Summary

This case involves the constitutionality of North Carolina's 2016 Congressional Redistricting Plan, which was challenged as an unconstitutional partisan gerrymander. The plaintiffs argued that the plan violated the Equal Protection Clause, the First Amendment, and Article I of the Constitution, and the court ruled in their favor. Legislative Defendants, members of the North Carolina General Assembly, sought a stay of the court's decision pending appeal to the Supreme Court, but the court denied their request, citing their failure to meet the necessary criteria for such relief. The court emphasized its responsibility to prevent further unconstitutional elections and the public interest in rejecting the stay, as the plan continued to harm voters. Distinct from other cases such as Whitford and Benisek, this case involved comprehensive evidence and applied to all thirteen congressional districts of North Carolina. The court also questioned the Legislative Defendants' authority to represent the state's interests, impacting their ability to claim irreparable harm. Ultimately, the court ordered the creation of a remedial plan to ensure compliance with constitutional standards before the 2018 elections, thus addressing the plaintiffs' urgent need for relief from the unconstitutional districting plan.

Legal Issues Addressed

Authority to Represent State Interests

Application: Legislative Defendants were found not to have the authority to represent the State's interests in federal election law cases, impacting their ability to demonstrate irreparable harm.

Reasoning: In a separate redistricting case, it has been asserted that Legislative Defendants do not have the authority to represent the General Assembly collectively, as they are individual legislators and not authorized spokespersons for the entire body.

Distinction from Related Supreme Court Cases

Application: The court distinguished this case from related Supreme Court cases, noting differences in standing, scope, and procedural posture, which justified not staying its order.

Reasoning: The Court's prior denial of a motion by Legislative Defendants to stay proceedings highlights significant differences between the current case and the Supreme Court cases of Whitford and Benisek.

Judicial Responsibility to Prevent Unconstitutional Elections

Application: The court emphasized its responsibility to prevent future elections under unconstitutional plans and denied a stay to avoid perpetuating harm to voters.

Reasoning: The Court has a responsibility to ensure that future elections are not held under unconstitutional plans, and past elections in 2012, 2014, and 2016 under such a plan heighten the potential prejudice to voters.

Public Interest Against Staying Court Orders

Application: The court found that the public interest strongly opposed staying its order, as the redistricting plan violated constitutional principles and inflicted harm on voters.

Reasoning: The public interest strongly opposes staying the Court's order, given that the 2016 Plan violates constitutional principles and inflicts public harms on voters in the affected districts.

Stay Pending Appeal

Application: The court evaluated the request for a stay pending appeal using four factors and found that the Legislative Defendants did not meet the heavy burden required for such extraordinary relief.

Reasoning: The Court evaluates four factors for issuing a stay pending appeal: (1) the likelihood of the applicant's success on the merits; (2) potential irreparable injury without a stay; (3) substantial injury to other parties from the stay; and (4) the public interest.

Unconstitutional Partisan Gerrymander

Application: The court determined that North Carolina's 2016 Congressional Redistricting Plan was an unconstitutional partisan gerrymander, violating various constitutional provisions.

Reasoning: On January 9, 2018, the Court determined that North Carolina's 2016 Congressional Redistricting Plan was an unconstitutional partisan gerrymander, violating the Equal Protection Clause of the Fourteenth Amendment, the First Amendment, and Article I of the Constitution.