Gentry Crowell, Secretary of State of Tennessee v. Richard Mader
Headline: Tennessee redistricting dispute revived as Court withdraws earlier dismissal, vacates the lower-court judgment without prejudice, and allows challenges to the new 1979 legislative map and fee claims to continue.
Holding: The Court grants rehearing, withdraws its prior dismissal order, and directs that the district court’s judgment be vacated without prejudice so the parties may continue to challenge Tennessee’s new legislative map or seek fees.
- Allows court challenges to Tennessee’s new 1979 legislative map.
- Permits the lower court to consider attorney-fee requests from the plaintiffs' lawyers.
- Keeps the case alive instead of dismissing it entirely.
Summary
Background
A group of plaintiffs challenged Tennessee’s senatorial districting. A federal trial court had invalidated the 1973 legislative map, enjoined elections under that map, and said it might reinstate a 1972 court-ordered map if the legislature did not act. The Tennessee legislature later passed a new districting plan effective June 6, 1979. When the State appealed, the parties told this Court that the new law mooted the specific issues on appeal and asked the appeal be dismissed.
Reasoning
The central question was whether the new legislation made the entire case disappear or only resolved the particular issues on appeal. The Court explained that the recent law did not moot the whole lawsuit; it only removed the specific appellate issue. Because the earlier order treated the whole case as moot, the Court withdrew that order, granted rehearing, and directed that the trial-court judgment be vacated without prejudice so further proceedings can go forward. The Court noted that the parties may still challenge the newly enacted plan or seek attorney’s fees in the lower court.
Real world impact
This decision keeps the dispute alive. Tennessee voters, state officials, and lawyers can still ask the trial court to review the new 1979 map or award fees to the plaintiffs’ lawyers. The ruling is procedural and not a final decision on the validity of any map; the lower court can hold more hearings and decide the merits or fee requests going forward.
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