Besinek v. Lamone, 585 U.S. 155

Appellants are Republican voters who sued, alleging Maryland’s 2011 Sixth Congressional District map was a partisan gerrymander enacted in retaliation for their political views.
Plaintiffs sought a preliminary injunction in May 2017 to prevent use of the 2011 map in future congressional elections and requested relief by August 18, 2017 to allow time for a new map before 2018.
The District Court denied the preliminary injunction on August 24, 2017 and stayed further proceedings pending this Court’s decision in Gill v. Whitford, finding plaintiffs had not shown likelihood of success or entitlement to emergency relief on the timetable requested.
The District Court emphasized plaintiffs’ long delay in seeking injunctive relief and the complications of motive-based discovery (legislative intent) added in a 2016 amended complaint.
The Supreme Court reviewed the denial for abuse of discretion and affirmed, stressing equitable factors for preliminary injunctions: plaintiffs’ lack of diligence, the public interest in orderly elections, and the prudence of awaiting this Court’s guidance in Gill.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a preliminary injunction should issue to prevent use of the 2011 map	Benisek: ongoing constitutional injury; injunction needed before 2018 elections	Lamone: plaintiffs delayed and injunction would disrupt elections; remedy premature	Denied — no abuse of discretion in refusing injunction
Whether plaintiffs exercised reasonable diligence in seeking relief	Benisek: delay excused by procedural complexity and discovery obstruction	Lamone: plaintiffs waited six years and pled retaliation claims only in 2016	Held against plaintiffs — undue, years-long delay weighed against injunction
Whether public interest favors injunctive relief given election timing	Benisek: urgent need to redistrict before 2018	Lamone: injunction risks disruption and chaos to electoral process	Held against plaintiffs — public interest and orderly elections counseled denial
Whether district court reasonably stayed action pending this Court’s decision in Gill	Benisek: sought immediate adjudication and remedy	Lamone: awaiting Supreme Court guidance on standards for partisan gerrymandering was prudent	Held for defendant — staying and awaiting guidance was within district court discretion

Winter v. Natural Resources Defense Council, 555 U.S. 7 (establishes preliminary injunction standard and discretionary equitable factors)
Holmberg v. Armbrecht, 327 U.S. 392 (diligence requirement in seeking equitable relief)
Lucas v. Townsend, 486 U.S. 1301 (noting exigencies and timing in election-related emergency relief)
Fishman v. Schaffer, 429 U.S. 1325 (per curiam; caution against disrupting elections and on timing of relief)
Purcell v. Gonzalez, 549 U.S. 1 (per curiam; respect for state electoral processes and minimizing court-ordered disruptions)
University of Tex. v. Camenisch, 451 U.S. 390 (preliminary injunction limited to preserving relative positions until trial)