Shapiro v. McManus
Headline: Court requires three-judge panels for constitutional challenges to congressional district maps, blocking single judges from dismissing such redistricting suits and protecting plaintiffs’ right to multi-judge review.
Holding:
- Requires referral of congressional redistricting challenges to three-judge panels.
- Limits single judges from dismissing meritorious apportionment claims.
- Preserves plaintiffs’ right to multi-judge review and direct Supreme Court appeal.
Summary
Background
After the 2010 Census, Maryland enacted a new map for its eight congressional districts in October 2011. A bipartisan group of citizens sued pro se, saying the map burdens their First Amendment right of political association, and asked a district judge to convene a three-judge court. The district judge dismissed the suit for failing to state a claim and did not notify the circuit chief judge to form a three-judge panel. The Fourth Circuit affirmed the dismissal, and the plaintiffs asked the Supreme Court to review the procedural question.
Reasoning
The Court considered whether a single district judge may refuse to start the process for a three-judge court under the statute that mandates three judges for challenges to congressional apportionment. The Court held that the statute’s mandatory language requires referral whenever a case challenges the constitutionality of congressional districting. The phrase in the procedures section allowing a judge to “determine that three judges are not required” is an administrative check to confirm the request actually fits the statute—not a license to resolve the merits by dismissing ordinary claims. Only claims that are “wholly insubstantial” or plainly frivolous may be dismissed without convening a three-judge court. Because the complaint here exceeded that very low threshold, the district judge erred.
Real world impact
Going forward, plaintiffs who challenge congressional maps are generally entitled to have their suits heard by three-judge district courts, limiting single-judge dismissals on the merits except in frivolous cases. This decision does not decide the merits of the redistricting claim; it sends the case back for the three-judge court to consider the substance of the allegations.
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