Tennant v. Jefferson County Commission

Summary

The Supreme Court held that West Virginia's 2011 congressional redistricting plan did not violate the Article I, §2, requirement of population equality among congressional districts. Applying Karcher v. Daggett, the Court concluded that the plan's 0.79% population variance was justified by legitimate state interests, including avoiding county splits, preventing incumbent contests, and minimizing population shifts. The Court reversed the District Court's judgment and remanded for consideration of the plaintiffs' claims under the West Virginia Constitution.

Holdings

1. The redistricting plan was constitutionally permissible because West Virginia carried its burden of showing that the minor population deviations were justified by legitimate state objectives.
2. The District Court erred in requiring the legislature to identify a discrete, numerically precise portion of the variance attributable to each districting policy.
3. The case was remanded for the District Court to address the remaining West Virginia constitutional claims in the first instance.

Questions Presented

1. Whether West Virginia's congressional redistricting plan violated Article I, § 2 of the Constitution because its 0.79% population variance could have been reduced.
2. Whether the State demonstrated under Karcher v. Daggett that the population deviations were necessary to achieve legitimate, consistently applied state districting objectives.
3. Whether the case should be remanded for consideration of the plaintiffs' separate claims under the West Virginia Constitution.

Disposition

reversed_and_remanded