Besinek v. Lamone
Headline: Court affirms denial of emergency order to block Maryland’s 2011 congressional map, making it harder for delayed challengers to force a new map before upcoming elections.
Holding:
- Makes it harder for delayed challengers to quickly force new election maps.
- Courts may deny emergency relief when plaintiffs waited years to seek it.
- Prioritizes orderly election schedules over last-minute map changes.
Summary
Background
Several Republican voters sued Maryland election officials, saying the State’s 2011 map for the Sixth Congressional District was drawn to retaliate against them for their political views. In May 2017, six years after the map was drawn, they asked the District Court for a preliminary injunction to stop elections under that map and gave August 18, 2017 as a deadline so a new map could be prepared. The District Court denied the request on August 24, 2017 and stayed further proceedings while this Court considered related partisan gerrymandering claims in Gill v. Whitford.
Reasoning
The Supreme Court reviewed whether the District Court abused its discretion by denying that emergency relief. The high court explained that preliminary injunctions are extraordinary and require more than a likely victory on the merits: applicants must also act with reasonable diligence and show that an injunction serves the public interest. The Court found plaintiffs had waited years—three elections and more than three years after their initial complaint—and only pressed the specific retaliation theory in 2016, which required additional discovery into legislative intent. Although legislators’ assertion of privilege slowed discovery, the Court concluded the delay was largely the plaintiffs’ doing. The Court also emphasized the public interest in avoiding disruptive, last-minute changes to election procedures while this Court’s decision in Gill could provide important legal guidance. For these reasons, even assuming the plaintiffs might win, the balance of equities and the public interest weighed against a preliminary injunction.
Real world impact
The decision means courts may refuse emergency orders to redraw maps when challengers wait years to seek relief and when changes would disrupt election schedules. It affirms that courts consider both a challenger’s timeliness and the public interest in orderly elections before forcing map changes. This ruling addresses only the denial of immediate relief and does not decide the underlying constitutional claim; the merits could still be decided later.
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