Summary
The Illinois Supreme Court reviewed an original action challenging the 2001 legislative redistricting plan approved by the Illinois Legislative Redistricting Commission. The majority held that the challengers failed to establish that the plan violated the constitutional compactness requirement or was against the manifest weight of the evidence, and entered judgment for the defendants. Justices Thomas and Garman dissented, arguing that the plan should be remanded because of procedural deficiencies and insufficient consideration of compactness.
Topics
Practice areas
Questions Presented
- Whether the Illinois Legislative Redistricting Commission's 2001 redistricting plan violated the Illinois Constitution's compactness requirement.
- Whether the challengers established that the Commission's plan was against the manifest weight of the evidence and should be invalidated in favor of proposed alternative maps.
Holdings
- The challengers did not establish that the challenged legislative and representative districts failed the constitutional compactness requirement.
- A party challenging a redistricting plan approved and filed by the Illinois Legislative Redistricting Commission must show not only that its proposed alternative is superior, but also that the Commission's plan is against the manifest weight of the evidence.
Key quotations
“Legislative redistricting maps approved and filed under section 3 of article IV of the Illinois Constitution of 1970 (Ill. Const. 1970, art. IV, § 3) must meet four requirements.” (at 487)
“The fact that more compact formulations can be devised is not, however, a sufficient basis for invalidating a map duly approved and filed according to law.” (at 488)
“Even if a proposed alternative map would meet the other legal requirements, in addition to the requirement of compactness, parties opposing a redistricting plan approved and filed by the Commission must establish not only that their map is superior, but that the map approved by the Commission is against the manifest weight of the evidence.” (at 488)
Factual background
Following the 2000 federal decennial census, the Illinois Legislative Redistricting Commission approved and filed the Currie II legislative redistricting map. Illinois voters and intervening legislative leaders challenged the boundaries of several Senate and House districts, principally arguing that the districts were insufficiently compact. The challengers relied on visual comparisons and mathematical dispersion and perimeter tests, but did not address whether their proposed alternatives satisfied the other constitutional requirements of population equality, minority representation, contiguity, and political fairness.
Procedural history
Plaintiffs obtained leave under Illinois Supreme Court Rule 382 to file a complaint and later filed an amended complaint. The court permitted legislative leaders and other parties to intervene. The original and intervening plaintiffs sought a declaratory judgment invalidating the 2001 redistricting plan and an order requiring reconfiguration of specified districts. The Supreme Court denied the requests, entered judgment for defendants, and ordered its mandate to issue immediately.