Carter v. Chapman

Summary

The Pennsylvania Supreme Court selected a congressional redistricting plan for the 2022 elections after Pennsylvania lost a congressional seat following the 2020 Census and the General Assembly and Governor failed to agree on a replacement plan. Exercising original jurisdiction, the Court declined to adopt the Special Master’s recommended plan and adopted the plan submitted by the Carter Petitioners. The opinion discusses population equality, compactness, contiguity, political-subdivision splits, communities of interest, partisan fairness, and compliance with the Pennsylvania Constitution and Voting Rights Act.

Holdings

1. The 2018 congressional redistricting plan was unconstitutional because it created eighteen districts based on the 2010 Census even though Pennsylvania was entitled to only seventeen congressional districts after the 2020 Census.
2. When the political branches are unable to enact a timely congressional redistricting plan, the judiciary may select a constitutionally valid plan, and the Supreme Court may assume plenary jurisdiction to do so.
3. A judicially selected congressional redistricting plan must satisfy the traditional core criteria of compactness, contiguity, population equality as nearly equal as practicable, and minimization of political-subdivision divisions; it may also consider subordinate historical factors, must avoid vote dilution under Pennsylvania's Free and Equal Elections Clause, and must comply with the Voting Rights Act.
4. The Carter Plan was superior or comparable to the other submitted plans and satisfied the governing redistricting criteria; it was adopted as Pennsylvania's 2022 Congressional Redistricting Plan.
5. The Carter Plan's maximum two-person population deviation was permissible because it resulted from a good-faith effort to avoid an additional split of a vote-tabulation district, a legitimate state objective.

Questions Presented

1. Whether Pennsylvania's 2018 congressional redistricting plan became unconstitutional after the 2020 Census reduced the Commonwealth's congressional delegation from eighteen to seventeen seats.
2. Whether the Supreme Court of Pennsylvania could assume plenary jurisdiction and select a congressional redistricting plan when the General Assembly and Governor failed to enact one.
3. What criteria govern the judicial selection of a replacement congressional redistricting plan under Pennsylvania's Free and Equal Elections Clause.
4. Whether the Carter Plan satisfied the traditional core redistricting criteria, subordinate historical considerations, partisan-fairness requirements, and the Voting Rights Act.
5. Whether a two-person maximum population deviation was permissible when justified by avoiding an additional split of a vote-tabulation district.

Disposition

other