Arizona State Legislature v. Arizona Independent Redistricting Comm'n
Headline: Ruling allows Arizona’s voter-created independent redistricting commission to draw congressional districts, affirming the commission’s maps and rejecting the state legislature’s constitutional challenge under the Elections Clause.
Holding:
- Allows voter-created independent commissions to set congressional district maps in Arizona.
- Confirms states may use initiatives to prescribe rules for federal elections.
- Leaves the legislature able to sue when its redistricting authority is removed.
Summary
Background
Arizona voters adopted Proposition 106 in 2000 to take redistricting power away from the state legislature and give it to an independent Arizona Independent Redistricting Commission (AIRC). After the 2010 census the AIRC adopted congressional maps in January 2012. On June 6, 2012, the Arizona Legislature sued, arguing the word "Legislature" in the Constitution’s Elections Clause means only the elected legislative body and therefore the initiative-created commission could not lawfully draw congressional districts. A three-judge District Court held the Legislature had standing but dismissed the claim on the merits by a 2–1 vote.
Reasoning
The Court first held the Arizona Legislature has standing to sue when its loss of redistricting power is concrete. On the merits the majority explained that a State’s lawmaking power can include the people acting by initiative, and that federal statutory language (2 U.S.C. § 2a(c)) and historical precedents permit a State to use the lawmaking method its constitution prescribes. The Court relied on earlier decisions (including Davis/Hildebrant, Hawke, and Smiley) and on the history and purpose of the Elections Clause to conclude the Elections Clause does not bar Arizona from using an initiative-created commission to adopt congressional districts.
Real world impact
The decision allows the AIRC’s maps to govern congressional elections so long as they comply with the U.S. Constitution and federal law. It recognizes that citizens, via initiative, may be a lawful source of state redistricting rules. The Legislature retains the ability to sue when its institutional powers are displaced.
Dissents or concurrances
A dissent argued "Legislature" in the Elections Clause means the representative legislative body only, and would have struck down the commission and criticized the Court’s broad reading of the Clause.
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