Hall v. Moreno, 2012 CO 14

Colorado's 2010 census showed malapportioned seven congressional districts; General Assembly failed to enact a new map in time for elections.
Trial court adopted the Moreno/South Map as a judicial remedy, finding it satisfied constitutional and statutory criteria.
Multiple parties and amici submitted maps; the trial court conducted a ten-day trial with extensive evidence and testimony.
The Colorado Supreme Court granted certiorari to review the trial court’s Moreno/South Map—focusing on whether the map complies with law and criteria.
The Court sets forth the scope of review: it will not redraw a map but will assess the trial court’s adopted remedy under open-ended statutory factors; it ultimately affirms that the Moreno/South Map reasonably balances the factors.
The opinion concludes with a holding that the Moreno/South Map is lawful and that the district court did not abuse its discretion in adopting it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Moreno/South Map satisfy constitutional and statutory criteria?	Moreno Plaintiffs contend the map meets population equality and Voting Rights Act requirements.	Respondents contend the map adheres to constitutional and statutory directives and balances factors.	Yes; the map satisfies the applicable constitutional and statutory criteria.
Did the trial court properly balance the non-constitutional factors?	Hall Plaintiffs argue the court undervalued minimization of disruption and overemphasized other factors.	Court correctly weighed preservation of communities of interest, subdivision integrity, compactness, and other factors.	Yes; the balancing was reasonable under 2-1-102(1)(b) and not an abuse of discretion.
Was the trial court's remedial plan permissible given open-ended factors?	The plan was a legitimate remedy to cure malapportionment.	Court had broad discretion to select a lawful remedy within statutory factors.	Yes; the remedy was lawful and within the court’s discretion.

Wesberry v. Sanders, 376 U.S. 1 (1964) (constitutional requirement of equal population in House districts)
Reynolds v. Sims, 377 U.S. 583 (1964) (one person, one vote doctrine in state/federal contexts)
Beauprez v. Avalos, 42 P.3d 642 (Colo. 2002) (abuse-of-discretion review of redistricting remedy in Colorado)
Gaffney v. Cummings, 412 U.S. 785 (1973) (court may consider non-neutral factors in reapportionment)
Carstens v. Lamm, 543 F.Supp. 68 (D. Colo. 1982) (communities of interest and districting considerations in Colorado)