State ex rel. Teichman v. Carnahan, 357 S.W.3d 601

Teichman, a Missouri voter, sought a writ prohibiting the Secretary of State from using any Senate plan/map from the nonpartisan reapportionment commission.
The commission withdrew its original plan and filed a revised plan arguing a constitutional provision on multi-district counties required revision.
Teichman challenged the commission’s authority to withdraw and replace the plan, and alleged the original plan violated art. Ill, sec. 7 by crossing county lines.
The constitution requires the bipartisan commission to file a final plan within six months; failure triggers appellate judges to file a plan within 90 days.
The court held the commission had no authority to revise after signing/fileting the original plan and that the original violated the County-crossing restriction.
A writ of prohibition against the Secretary of State was issued to prevent use of either plan; process must restart under art. Ill, § 7.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to withdraw and revise plan	Teichman contends the commission lacked power to withdraw and file a revised plan.	Teichman argues the commission could revise when constitutionally infirm.	Commission had no authority to revise; original plan invalid.
Constitutional compliance of original plan	Original plan violated art. Ill, § 7 by crossing counties more than once.	Commission acted under constitutional constraints; plan attempted to follow multi-district county rule.	Original plan violated the county-crossing restriction; invalid.
Proper remedy	If invalid, process restart per art. Ill, § 7 should occur.	Alternative remedies unnecessary since authority to revise was lacking.	Writ of prohibition issued; proceed restart of redistricting.

Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824 (Mo. banc 1990) (election-related timeliness and remedial writs context)
State ex rel. Gralike v. Walsh, 483 S.W.2d 70 (Mo. banc 1972) (election law and redistricting context)
Preisler v. Doherty, 365 Mo. 460, 284 S.W.2d 427 (1955) (early redistricting and constitutional constraints)
Preisler v. Hearnes, 362 S.W.2d 552 (Mo. banc 1962) (limits on legislative reapportionment; functus officio relevance)
State ex rel. Jones v. Atterbury, 300 S.W.2d 806 (Mo. banc 1957) (functus officio doctrine application)
Armentrout v. Schooler, 409 S.W.2d 138 (Mo. banc 1966) (jurisdiction for legislative reapportionment as justiciable issue)
Ashcroft v. Blunt, 696 S.W.2d 329 (Mo. banc 1985) (original remedial writs and election timing context)