Wilson v. State ex rel. State Election Board
2012 OK 2
| Okla. | 2012Background
- Senator Wilson petitioned district court to invalidate the 2011 Act (SB 821) under Article V, §9A, alleging the apportionment failed to preserve factors like population, compactness, and local interests.
- In Wilson I, this Court rejected challenges to the 2011 Act as unconstitutional and addressed eligibility standards and the district court's jurisdiction over political gerrymandering claims.
- The district court dismissed on preclusion and lack of jurisdiction grounds, agreeing the issue was resolved in Wilson I.
- Senator Wilson filed replies arguing Wilson I did not resolve coalition of local-interest factors and that the 9A factors remain enforceable in district court.
- This Court affirms, holding Senator Wilson failed to state a cognizable claim and is barred by claim preclusion from relitigating the same theories from Wilson I.
- The concurrence clarifies that voter-equality claims can be adjudicated under 11C–11D procedures, and that such claims are not barred from future consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court lacked jurisdiction due to preclusion | Wilson relies on Wilson I to preserve district-court review | Defendants say Wilson I resolves the issue via preclusion | Yes; district court properly dismissed on preclusion grounds |
| Whether local-interest factors remain enforceable under §9A | Wilson argues §9A factors must guide feasible consideration | Defendants contend §9A language is not so restrictive | No cognizable claim; failure to allege non-feasibility state interests |
| Whether the claim was properly dismissed for failure to state a claim | Wilson asserts valid §9A challenge based on 2011 Act | Record shows no stateable claim after Wilson I and preclusion | Dismissal proper; no relief due to failure to state a claim and preclusion |
| Whether the 60-day deadline under Article V, §11C, affects disposition | Senator Wilson contends timely challenge | Court need not reach time-bar due to other dispositive grounds | Not reached; dismissal upheld on other grounds |
Key Cases Cited
- Wilson v. Fallin, 2011 OK 76 (Okla. 2011) (upholding constitutionality of 2011 Act under §9A; discusses jurisdiction and standards in Wilson I)
- Reynolds v. Sims, 377 U.S. 533 (U.S. 1964) (review of apportionment under equal protection; county-based scheme invalidated)
- Read v. Read, 57 P.3d 561 (Okla. 2001) (claim preclusion scope in res judicata context)
- Feightner v. Bank of Okla., 65 P.3d 624 (Okla. 2008) (preclusion determination procedures and law)