In re Stovall

Summary

The Kansas Supreme Court reviewed the validity of 2002 Substitute for Senate Bill 256, which reapportioned the state's 40 senatorial districts. The court upheld the plan, concluding that its enactment procedure was adequate and that the districts satisfied constitutional requirements concerning population equality, contiguity, compactness, and voting rights.

Holdings

1. The enactment procedure for 2002 Substitute for Senate Bill 256 was constitutionally and statutorily valid because no violation of constitutional or statutory law, and no failure to follow applicable legislative rules, was shown.
2. The 9.27 percent overall population deviation in the Senate reapportionment plan did not violate the one-person-one-vote principle guaranteed by the Equal Protection Clause of the Fourteenth Amendment.
3. The Kansas Senate districts created by 2002 Substitute for Senate Bill 256 did not appear to violate the Voting Rights Act.
4. The districts were sufficiently compact and contiguous, and the court found no districting violation requiring a special explanation for political gerrymandering or invidious discrimination.

Questions Presented

1. Whether the procedure by which 2002 Substitute for Senate Bill 256 was enacted complied with constitutional, statutory, and legislative requirements.
2. Whether the Senate reapportionment plan violated the one-person-one-vote principle under the Equal Protection Clause of the Fourteenth Amendment.
3. Whether the plan violated the Voting Rights Act.
4. Whether the districts were sufficiently compact and contiguous and avoided constitutionally impermissible political gerrymandering or invidious discrimination.

Disposition

approved