Shapiro v. McManus
The Court ruled that a federal law requiring a three-judge panel to hear challenges to congressional district maps leaves a single judge no discretion to dismiss the case alone, once the lawsuit actually challenges a congressional map's constitutionality.
The decision reverses a Maryland gerrymandering case that a single judge had thrown out on the merits, holding that only a three-judge panel could make that call, and clarifies how demanding the screening standard for such claims can be.
“It follows that the district judge was required to refer the case to a three-judge court, for § 2284(a) admits of no exception”
The Court's core holding that the three-judge-court requirement is mandatory, not discretionary.
How it got here: A single federal district judge dismissed the suit instead of convening a three-judge panel; the Fourth Circuit summarily affirmed, and the voters asked the Supreme Court to review the dismissal.
The Case in Depth
What happened
A bipartisan group of Maryland voters sued without lawyers, arguing that the state's 2011 congressional redistricting map was gerrymandered in a way that burdened their First Amendment right to political association. They asked for a special three-judge court, as federal law requires for suits challenging congressional district maps.
The question before the Court
When voters sue over a state's congressional map as unconstitutional, must a single judge hand the case to a special three-judge panel instead of dismissing it alone?
Why it matters
People challenging congressional or state legislative maps as unconstitutional now know their case must go before a three-judge panel rather than being screened out by a single judge, and that any direct appeal goes straight to the Supreme Court. This preserves a faster, more protected path for redistricting challenges and limits a single judge's power to end such suits alone.
What changes now
The case returns to the district court, where a three-judge panel — not a single judge — must now consider the Maryland voters' gerrymandering claim. This is a final ruling on the procedural question of who may hear such claims, though the underlying merits of whether Maryland's map is unconstitutional remain undecided and will be litigated further before that panel.
What this does not decide
The Court expressly took no position on whether Maryland's congressional map actually violates the First Amendment. It decided only that the case could not be dismissed by a single judge and must instead be heard by a three-judge panel, leaving the merits question open.
How the Court got there
The legal reasoning, step by step
- The Court read the three-judge-court statute's opening command — that such a court 'shall be convened' whenever a suit challenges a congressional map's constitutionality — as leaving no room for a single judge's discretion, because the word 'shall' ordinarily creates a duty courts cannot sidestep.
- The Court then explained that a later clause letting a judge decide 'three judges are not required' is not a loophole allowing a single judge to reject the case on the merits; instead, it is a housekeeping check confirming the suit truly is the kind of case the mandatory rule covers.
- Supporting that reading, the Court pointed to a separate part of the same law barring a single judge from ever entering judgment on the merits in these cases, reasoning it would be inconsistent to let a judge do indirectly, through dismissal, what the statute plainly forbids doing directly.
- The Court then addressed a narrower judge-made exception allowing dismissal without a panel when a constitutional claim is not just weak but 'wholly insubstantial and frivolous' — a jurisdictional test wholly separate from asking whether a complaint states a winning claim on the merits.
- Applying that narrow test, the Court found the voters' First Amendment theory tracked an approach a sitting Justice had floated in a prior gerrymandering case and had never been rejected by a majority, so it could not be dismissed as frivolous or insubstantial.
- The Court concluded that because the case was neither frivolous nor outside the statute's mandatory coverage, it had to go before a three-judge panel rather than being dismissed by one judge alone.
Doctrinal impact
Cases affected by this decision
Reaffirms Goosby v. Osser (409 U.S. 512)
Its narrow 'wholly insubstantial' screening test still applies, but only to jurisdiction, not to merits dismissals.