Branigin v. Grills
Headline: Court denies stay and lets a federal court’s new Indiana congressional districts stand, forcing quick elections under judge-drawn maps and blocking the State Legislature from delaying changes.
Holding:
- Judge-drawn congressional districts will be used in Indiana’s imminent primary and general elections.
- State Legislature cannot delay implementing new districts before candidate filing deadline.
- Sets precedent for courts imposing maps when legislatures fail to act quickly.
Summary
Background
The State Election Board of Indiana and others asked the Justices to pause a three-judge federal court’s order that created new districts for Indiana’s 11 members of the U.S. House. The District Court had found the 1965 legislative map unconstitutional and, after this Court’s earlier remand, replaced many legislative boundaries with its own plan. The State Legislature did not adopt a new plan before it adjourned, and important filing and primary deadlines were approaching.
Reasoning
The core question was whether the Court should block the District Court’s new map while the matter received fuller review. The Court denied the stay. Justice Harlan explained he disagreed with judges imposing their own apportionment plans without clearer national guidance, but he agreed to deny the stay because of the urgent calendar: candidate filing ends March 27, 1968, and a primary was set for May 7, 1968. Granting a stay would likely leave Indiana without any legally usable plan for upcoming elections.
Real world impact
As a practical matter, the judge-drawn districts will govern Indiana’s imminent candidate filings and primary unless the legislature acts quickly or the Court later changes course. The decision preserves the District Court’s timetable so elections can proceed on schedule. This is a temporary, emergency resolution tied to election timing rather than a final ruling on all legal questions.
Dissents or concurrances
Judge Dillin on the District Court preferred only minimal changes to the legislative map to reduce population differences. Justice Harlan noted his broader concern with courts replacing legislative districting without plenary review, but he agreed to deny the stay for practical reasons.
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