In re Reapportionment of Towns of Woodbury & Worcester

Summary

The Vermont Supreme Court denied a challenge by residents of Woodbury and Worcester to the Legislature’s 2002 reapportionment plan placing their towns in the Lamoille-Washington-1 district. The Court held that the district satisfied constitutional and statutory requirements, including geographic contiguity, compactness, political-subdivision boundaries, and consideration of common interests, and that the petitioners failed to overcome the deferential standard of review.

Holdings

1. The petitioners failed to meet their heavy burden of showing that the district lacked a rational or legitimate basis under the constitutional and statutory reapportionment criteria. The district was contiguous and relatively compact, county-line crossings were not independently invalid, and the record showed sufficient common ties among the member towns.
2. Remand was not required. The court found that the board and Legislature considered all required criteria, and any deficiency in the record concerning off-the-record legislative discussions did not warrant remand because the district independently satisfied the constitutional and statutory criteria.
3. The population disparity did not establish unconstitutional disenfranchisement because petitioners failed to show that they lacked an opportunity to influence the election or secure the attention of a winning candidate.

Questions Presented

1. Whether placing Woodbury and Worcester in the Lamoille-Washington-1 district violated constitutional and statutory requirements concerning geographical compactness, contiguity, county and political-subdivision boundaries, and common social, economic, and political interests.
2. Whether the reapportionment plan had to be remanded because the legislative record did not expressly reveal the factors considered or the weight assigned to each nonnumerical criterion.
3. Whether the disparity in population among towns within the two-member district effectively disenfranchised residents of Woodbury and Worcester.

Disposition

other