Rucho v. Common Cause, 139 S. Ct. 2484

Background

Two consolidated suits: Rucho v. Common Cause (NC) and Lamone v. Benisek (MD) challenged congressional maps as unconstitutional partisan gerrymanders (NC plaintiffs said map disadvantaged Democrats; MD plaintiffs said map disadvantaged Republicans).
District courts found maps unconstitutional under Equal Protection and/or First Amendment and enjoined the plans; defendants appealed directly to the Supreme Court under 28 U.S.C. §1253.
North Carolina facts: Republican legislators instructed a mapmaker to draw a map to produce a 10–3 Republican advantage; districts were challenged as products of systematic cracking and packing.
Maryland facts: Democratic officials redesigned the Sixth District by moving hundreds of thousands of residents (far beyond the minimal population adjustment) to flip a reliably Republican seat; plaintiffs alleged First and Elections Clause violations.
The Supreme Court considered whether partisan-gerrymandering claims are justiciable and, if so, what judicially manageable standard would apply; it vacated and remanded the district-court judgments and dismissed for lack of jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are partisan-gerrymandering claims justiciable in federal court?	Courts can and should redress extreme partisan gerrymanders as judicially cognizable constitutional wrongs.	Such claims present nonjusticiable political questions lacking judicially discoverable and manageable standards.	Held: Nonjusticiable — political question beyond federal courts' competence; dismiss for lack of jurisdiction.
Do excessive partisan gerrymanders violate the Equal Protection Clause (vote dilution)?	Rucho/Lamone: maps intentionally diluted votes of a political group (predominant intent + durable effects), so Equal Protection is violated.	Defendants: Partisan motivation alone is permissible; no manageable constitutional standard to judge "how much is too much."	Held: Courts cannot adopt a judicially manageable, politically neutral standard for partisan vote-dilution claims; therefore not for federal courts to decide.
Do maps violate the First Amendment (burden on political association/speech)?	Plaintiffs: maps burden political speech and association by diminishing ability to elect and by chilling organization/funding/volunteering.	Defendants: Districting does not restrict speech/association; holding the intent-to-burden test would outlaw ordinary partisan considerations.	Held: First Amendment framework offered by plaintiffs lacks clear, manageable boundaries; not an available federal judicial remedy here.
Do the Elections Clause or Article I, §2 create judicially enforceable limits on partisan considerations?	Plaintiffs: extreme partisan maps usurp the people’s right to choose representatives and exceed state legislative Elections Clause authority.	Defendants: Elections Clause assigns these matters to state legislatures and Congress; it does not furnish judicially enforceable limits.	Held: Neither provision provides a judicially manageable limit on partisan considerations; these are political-branch matters.

Key Cases Cited

Marbury v. Madison, 5 U.S. 137 (1803) (establishes judicial duty to "say what the law is")
Baker v. Carr, 369 U.S. 186 (1962) (political-question doctrine; lack of judicially manageable standards defeats justiciability)
Vieth v. Jubelirer, 541 U.S. 267 (2004) (plurality/concurrence: no agreed judicial standard for partisan-gerrymandering claims; Kennedy left open possibility a standard might emerge)
Wesberry v. Sanders, 376 U.S. 1 (1964) (one-person, one-vote principle for congressional districts)
Gomillion v. Lightfoot, 364 U.S. 339 (1960) (racially motivated boundary-drawing unconstitutional)
Davis v. Bandemer, 478 U.S. 109 (1986) (plurality/split: partisan-gerrymandering claims divisible but Court could not agree on manageable standard)
Gaffney v. Cummings, 412 U.S. 735 (1973) (recognizes political considerations as inevitable in districting; proportional-aimed plans not per se unconstitutional)
Miller v. Johnson, 515 U.S. 900 (1995) (race-based districting subject to strict scrutiny; distinguishes racial from political classifications)
Reynolds v. Sims, 377 U.S. 533 (1964) (vote dilution undermines equal participation; foundation for one-person, one-vote doctrine)