League of Women Voters of Chi v. City of Chicago, 2014 U.S. App. LEXIS 13071

Background

After the 2010 census, Chicago sought to reapportion its 50 aldermanic wards under state law.
In 2012 the City Council approved the 2015 ward map by a vote of 41–8.
The League of Women Voters and 14 Chicago residents challenged the map as violating equal-population principles.
They alleged the map deviated up to 8.7% from the average ward population and that this violated the Fourteenth Amendment.
The district court dismissed Counts I (premature implementation) and III (equal-population deviation) for failure to state a claim, and the League appealed.
The court reviews a 12(b)(6) dismissal de novo and applies the standard that plausibly pleaded claims survive if supported by facts.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether premature implementation violated equal protection.	League argues early enactment denied voters equal protection.	City contends no constitutional injury without formal policy or law.	Counts dismissed; no equal-protection breach shown.
Whether 8.7% maximum population deviation creates an equal-protection violation.	League contends deviations below 10% can be discriminatory.	City contends minor deviations are presumptively valid absent arbitrariness.	No violation; deviations under 10% are presumptively constitutional absent arbitrariness.
Whether evidence of targeting independent aldermen supports an equal-protection claim.	League asserts map targeted independent aldermen in Second and Thirty-Sixth Wards.	Political boundaries can be partisan without constitutional injury; evidence insufficient.	Not enough to overcome presumption of constitutionality.
Whether the map departed from traditional redistricting criteria to create constitutional injury.	League claims failure to adhere to criteria shows arbitrariness.	Non-discriminatory criteria may justify minor deviations; compactness is not mandatory.	Traditional criteria cannot alone prove an equal-population violation; claim rejected.
Whether the Monell claim for early implementation states a municipal §1983 violation.	League claims city policy or unwritten custom caused injury.	There must be an express policy, widespread custom, or final policymaker action.	Limited evidence of policy; claim fails.

Key Cases Cited

Reynolds v. Sims, 377 U.S. 533 (U.S. (1964)) (one person, one vote; equal pop. districts required but not mathematically exact)
Wesberry v. Sanders, 376 U.S. 1 (U.S. (1964)) (vote equality principle; districts as equal as practicable)
Gaffney v. Cummings, 412 U.S. 735 (U.S. (1973)) (no precision in population needed; minor deviations may be permissible)
Brown v. Thomson, 462 U.S. 835 (U.S. (1983)) (ten percent deviation creates prima facie case; under ten percent presumed valid)
White v. Regester, 412 U.S. 755 (U.S. (1973)) (minor deviations generally not constitutional violations without arbitrariness)
Karcher v. Daggett, 462 U.S. 725 (U.S. (1983)) (traditional criteria may justify minor deviations if nondiscriminatory)
Shaw v. Reno, 509 U.S. 630 (U.S. (1993)) (traditional principles may inform gerrymandering claims; not required but relevant)