287 F. Supp. 3d 558
M.D. Pa.2018Background
- After the 2010 census Pennsylvania enacted a 2011 congressional map; in January–February 2018 the Pennsylvania Supreme Court held the 2011 Map violated the state constitution and set deadlines for the General Assembly and Governor to adopt a remedial map, adopting its own remedial map on Feb. 19, 2018 when the legislature and governor did not enact a plan.
- Plaintiffs were two Pennsylvania state senate leaders (in their official capacities) and eight Republican U.S. Representatives; they sued state election officials in federal court claiming the Pennsylvania Supreme Court violated the federal Elections Clause by imposing redistricting criteria and by not giving the legislature adequate time to act.
- Plaintiffs sought injunctive relief directing state executive officials to use the 2011 Map for the 2018 elections instead of the court-drawn map.
- Defendants (the executive officials) and intervenors raised threshold defenses: lack of Article III standing, prudential (third‑party) standing, Rooker–Feldman and other abstention doctrines, preclusion and estoppel, and failure to state a claim on the merits.
- The district court conducted expedited briefing and a hearing, then dismissed the verified complaint for lack of standing (both Article III and prudential), holding the alleged Elections Clause injuries belonged to the Pennsylvania General Assembly and not to the plaintiffs and that amendment would be futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state-senator plaintiffs have Article III standing to challenge alleged usurpation of legislative redistricting power | Senators (Corman, Folmer) claim institutional injury to legislature and loss of opportunity to craft remedial map | Injury is institutional and shared by all legislators; individual senators cannot sue (Raines) | Dismissed: senators lack Article III standing (their alleged injury is the legislature's and affects all members equally) |
| Whether U.S. Representative plaintiffs have Article III standing based on altered districts and wasted campaign resources | Reps argue redrawn districts reduce incumbency advantage and waste campaign investments | Elected officials have no cognizable personal interest in district composition; alleged injuries are not fairly traceable to the specific Elections Clause claims pleaded | Dismissed: Representatives lack standing (injury‑in‑fact and causation fail) |
| Whether plaintiffs may assert the General Assembly’s Elections Clause rights (prudential/third‑party standing) | Plaintiffs argue General Assembly cannot effectively vindicate its rights in state court after losing | Defendants point out the General Assembly was a party in state proceedings, had counsel, and has pending emergency relief to the U.S. Supreme Court—no hindrance to vindication | Dismissed: prudential third‑party standing unavailable because the General Assembly is not hindered from protecting its rights |
| Relief requested (injunction requiring use of 2011 Map) — justiciability and remedy | Plaintiffs ask federal court to enjoin enforcement of state-court map and require use of 2011 Map | Defendants: federal court lacks jurisdiction; remedy would intrude on state court judgment and political question/standing limits | Denied as moot by jurisdictional defect: court lacked authority to grant requested relief; complaint dismissed without leave to amend |
Key Cases Cited
- Raines v. Byrd, 521 U.S. 811 (legislators lack standing to assert institutional injury shared equally by all members)
- Coleman v. Miller, 307 U.S. 433 (legislators whose votes would have changed outcome may have standing in limited circumstances)
- Ariz. State Legislature v. Ariz. Indep. Redistricting Comm’n, 135 S. Ct. 2652 (state legislature has standing to challenge a structural transfer of its redistricting authority)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (standing requires concrete injury-in-fact)
- Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (federal court must dismiss when lacking subject‑matter jurisdiction)
- Lexmark Int’l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (distinguishing Article III standing from prudential limits like third‑party standing)
- Finkelman v. Nat’l Football League, 810 F.3d 187 (Third Circuit discussion of injury, causation, redressability in standing analysis)