Moore v. Harper, 380 N.C. 317

Summary

The Supreme Court held that the Elections Clause does not give state legislatures exclusive and independent authority to regulate federal elections free from restrictions imposed by state law. State legislatures remain subject to state constitutional constraints and ordinary state judicial review when prescribing rules for federal elections. The Court affirmed the judgment of the Supreme Court of North Carolina and held that it had jurisdiction despite subsequent state-court proceedings.

Holdings

1. The Court had jurisdiction under Article III and 28 U.S.C. § 1257(a) because Harper I's judgment enjoining use of the 2021 congressional maps remained operative, the legislative defendants continued to have a personal stake, and the Federal Elections Clause issue had finally been decided by the State's highest court and survived subsequent proceedings.
2. The Elections Clause does not vest exclusive and independent authority in state legislatures to set rules governing federal elections free from restrictions imposed by state law. When state legislatures prescribe such rules, they remain subject to ordinary state constitutional constraints and state judicial review.
3. State courts may not transgress the ordinary bounds of judicial review so as to arrogate to themselves the power vested in state legislatures to regulate federal elections. The Court did not adopt a specific test for identifying such a violation.

Questions Presented

1. Whether the Supreme Court had jurisdiction to review the North Carolina Supreme Court's judgment in Harper I after subsequent state-court proceedings overruled Harper I's reasoning on state-law justiciability.
2. Whether the Federal Elections Clause insulates state legislatures from review by state courts for compliance with state constitutional law.
3. Whether state courts may exceed the ordinary bounds of judicial review and thereby arrogate to themselves the power vested in state legislatures to regulate federal elections.

Disposition

affirmed