Arizona Independent Redistricting Commission v. Brewer, 275 P.3d 1267

IRC is a five-member independent body tasked with drawing district maps, with four partisan appointees and a chair chosen from non-partisan nominees.
Mathis, an Independent, was elected Chair by the four partisan commissioners in early 2011, and the IRC began drafting maps and holding public meetings.
In Oct 2011, Governor Brewer notified all Commissioners of alleged substantial neglect of duty and gross misconduct, inviting responses.
On Nov 1, 2011 Acting Governor Bennett removed Mathis as IRC Chair, effective upon Senate concurrence of two-thirds.
Senate concurrent removal occurred later that day; Mathis and the IRC sought relief in this special action before the Arizona Supreme Court.
The Court accepted jurisdiction, determined the matter was justiciable, and ultimately reinstated Mathis as Chair.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Governor’s grounds for removal meet Section 1(10) standards	Mathis argues grounds show substantial neglect or gross misconduct.	Brewer argues grounds are met by open-meeting failures and grid-map concerns.	No; grounds fail to meet substantial neglect or gross misconduct.
Whether removal review is non-justiciable political question	Removal is subject to judicial review under constitutional standards.	Removal involves political branches and is non-reviewable.	Justiciable; courts may review whether removal complies with constitutional standards.
Whether the Governor and Senate can be relieved from judicial review due to separation of powers	Courts must interpret constitutional limits on removal even for independent commissions.	Interbranch balance grants deference to political branches, limiting judicial review.	Judicial review applied; the governor’s removal did not meet constitutional standards.

Forty-Seventh Legislature v. Napolitano, 213 Ariz. 482 (2006) (original jurisdiction to issue extraordinary writs against state officers)
Rios v. Symington, 172 Ariz. 3 (1992) (original jurisdiction for extraordinary writs against state officers)
Ingram v. Shumway, 164 Ariz. 514 (1990) (recognizes judicial role in constitutional challenges to executive actions)
Mecham v. Gordon (I), 156 Ariz. 297 (1988) (impeachment-like proceedings; limits on judicial review of legislative impeachment rules)
Mecham v. Arizona House of Representatives (II), 162 Ariz. 267 (1989) (impeachment-like removal cannot always be reviewed by courts when constitutional prerequisites are met)
Holmes v. Osborn, 57 Ariz. 522 (1941) (review of executive removals for cause; limits on distorting standards)
In re Zawada, 208 Ariz. 232 (2004) (examples of judicial review of misconduct in office)
Nixon v. United States, 506 U.S. 224 (1993) (political questions doctrine; limits on judicial review of political processes)
Chadha, INS v. Chadha (1983) (judicial review of legislative actions and separation-of-powers concerns)
Adams v. Comm'n on Appellate Court Appointments, 2011 (2011) (limits and exercise of original jurisdiction in appointments)