Holt v. 2011 Legislative Reapportionment Commission
620 Pa. 373
| Pa. | 2013Background
- This is the second direct appeal to the Pennsylvania Supreme Court challenging the LRC's 2012 Final Plan after Holt I directed remand.
- Holt I held the 2011 Final Plan was contrary to law and rejected the map’s population deviations and subdivision splits, prompting remand for a constitutional plan.
- The LRC produced a new 2012 Final Plan, contending it complies with Section 16, reduces splits, and respects communities of interest and the Voting Rights Act.
- Appellants (multiple voters and officials) challenge the 2012 Final Plan as unnecessary subdivision splits and noncompact/noncontiguous districts, arguing it remains unconstitutional.
- The Court reviews the plan de novo, evaluating the plan as a whole for compliance with Article II, Section 16, rather than isolated districts or splitter counts.
- The Court ultimately affirms Holt I’s framework, finds the 2012 Final Plan not contrary to law, and dismisses the appeals, holding the LRC used population data to create a constitutionally compliant map effective for the 2014 elections.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the 2012 Final Plan meet Article II, §16 constraints as a whole? | Holt argues plan splits, contiguity, and compactness violate §16. | LRC contends plan improves compactness/splits and balances §16 with other considerations. | Not contrary to law; plan sustains §16 as a whole. |
| May challengers introduce private alternate plans in review? | Challengers' alternatives show plan’s constitutional flaws. | Alternates are not required, and unvetted plans should not govern review. | Holt I partnership preserved; alternate plans may be used as evidence; final plan reviewed on overall compliance. |
| Can political considerations (e.g., community interests, incumbency) justify deviations from strict §16 requirements? | LRC’s political factors justify deviations from strict mathematical standards. | Political considerations are permissible but cannot override §16 constraints. | Constitutional constraints trump political factors if they violate §16; mapping must still comply with §16. |
| Does the 2012 Final Plan violate the Voting Rights Act or minority representation concerns? | Plan dilutes minority influence and underrepresents Latino voters. | Plan adequately protects minority voting rights and complies with the VRA as applied. | Plan complies with the Voting Rights Act. |
| Are the asserted contour/compactness issues a constitutional violation given Pennsylvania’s geography? | Polsby–Popper scores show substantially less compactness than alternatives. | Compactness must be balanced with population equality and subdivision integrity; rigid metrics are not controlling. | No constitutional violation; flexibility allowed due to geography and multiple competing factors. |
Key Cases Cited
- Holt v. 2011 Legislative Reapportionment Comm’n, 614 Pa. 364 (Pa. 2012) (set scope of review; held 2011 Plan contrary to law; alternate plans admissible evidence)
- Albert v. 2001 Legislative Reapportionment Comm’n, 567 Pa. 670 (Pa. 2002) (established plenary scope of review and burden on challengers)
- In re Reapportionment Plan, 442 A.2d 661 (Pa. 1981) (foundational precedent on subdivision splits and review scope)
- Specter v. Levin, 448 Pa. 1 (Pa. 1972) (contiguity and related redistricting considerations)
- Vieth v. Jubelirer, 541 U.S. 267 (U.S. Supreme Court, 2004) (recognizes political considerations in redistricting; cautions limits)
- Karcher v. Daggett, 462 U.S. 611 (U.S. Supreme Court, 1983) (preserving cores of prior districts; incumbency considerations not constitutionally mandated)
- Voinovich v. Quilter, 507 U.S. 146 (U.S. Supreme Court, 1993) (minor population deviations allowed; strict scrutiny for large disparities)
- Brown v. Thomson, 462 U.S. 835 (U.S. Supreme Court, 1983) (range of population deviations and equal protection considerations)