H. Dean Summers v. Pete T. Cenarrusa, Etc.
Headline: Idaho legislative-district challenge: Court vacated the lower-court judgment and sent the case back for reconsideration in light of recent reapportionment rulings, delaying final relief for residents and the state legislature.
Holding: The Court vacated the District Court’s judgment and returned the Idaho reapportionment case for further consideration under three recent Supreme Court reapportionment decisions.
- Sends Idaho legislative map back to the trial court for reevaluation under new guidance.
- Delays immediate changes to district lines or elections in Idaho.
- Requires the State to justify population deviations like base growth and student exclusions.
Summary
Background
A group of Idaho residents challenged the state's legislative district plan, saying some districts were too big or too small compared with the ideal population. They pointed to a total deviation of about 19.4 percent, with one district roughly 10.6 percent over and another about 8.8 percent under. The State and the District Court said the differences were justified by factors such as population growth at Mountain Home Air Force Base, an anticipated irrigation-driven population increase, and excluding out-of-state or foreign college students from the voting population count.
Reasoning
The Supreme Court did not resolve who was right on the merits. Instead it vacated the District Court’s judgment and sent the case back for the lower court to reconsider the matter in light of three recent Supreme Court reapportionment decisions. The Court signaled that those precedents must guide how the District Court evaluates claimed justifications for population deviations and whether the legislative plan is acceptable.
Real world impact
The ruling requires the trial court to reexamine the Idaho plan under the newer guidance, so any immediate change to district lines is put on hold. The lower court and state will need to show whether specific reasons—like military base growth or treating college students as nonresidents—adequately justify the population differences.
Dissents or concurrances
Justice White, joined by the Chief Justice, dissented, arguing the case should have been affirmed because the jurisdictional statement failed to show real errors and the District Court reasonably accepted the State’s explanations.
Opinions in this case:
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