Florida Senate v. Forman

Summary

The Supreme Court of Florida reviewed a circuit court judgment declaring the Florida Senate redistricting plan unconstitutional as a political gerrymander. The court held that Marion County voters were not an identifiable political group under the applicable political-gerrymandering standard and had not shown an actual discriminatory effect or disenfranchisement. It reversed the circuit court’s judgment, explaining that compactness and preservation of communities of interest are not constitutionally required redistricting principles.

Holdings

1. Voters or residents of a political subdivision such as Marion County do not qualify, on the record and authorities presented, as an identifiable political group for purposes of a political-gerrymandering equal protection claim.
2. The circuit court erred in finding an actual discriminatory effect because dividing Marion County among four senate districts did not deprive its voters of a fair opportunity to influence the political process or establish that they had been shut out of that process.
3. Neither the United States Constitution nor the Florida Constitution requires the Legislature to draw compact legislative districts or preserve communities of interest.

Questions Presented

1. Whether voters or residents of Marion County constitute an identifiable political group for purposes of a political-gerrymandering equal protection claim.
2. Whether dividing Marion County into four senate districts established the actual discriminatory effect required under the political-gerrymandering test.
3. Whether the Florida or United States Constitution requires legislative districts to be compact or to preserve communities of interest.

Disposition

reversed