Wittman v. Personhuballah
578 U.S. 539
SCOTUS2016Background
- Virginia adopted a 2013 congressional redistricting plan (the Enacted Plan); voters from CD3 sued, alleging an unconstitutional racial gerrymander.
- A three-judge District Court agreed and struck down the Enacted Plan; the Commonwealth did not appeal.
- Ten Members of Congress intervened to defend the Enacted Plan; three (Forbes, Wittman, Brat) claim standing to appeal the district court judgment to the Supreme Court.
- After remand and further proceedings, the District Court issued a remedial plan when the legislature failed to act; the Special Master’s Remedial Plan was approved and implemented.
- The Supreme Court asked supplemental briefing on whether the intervenor-members independently satisfy Article III standing; the Court concludes none do and dismisses the appeal for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do intervenor Members of Congress have Article III standing to appeal the district court’s invalidation of the Enacted Plan? | Intervenors argue the District Court’s order will redraw districts and injure their reelection prospects; thus they suffer an injury fairly traceable to the judgment and redressable by reversal. | Respondents (and record) show no evidence that intervenors independently suffered an injury; the Commonwealth did not appeal; intervenors must independently meet Article III. | No—intervenors lack standing; appeal dismissed. |
| Is Representative Forbes’ claimed injury redressable? | Forbes claimed he would return to run in his old district (CD4) if the Enacted Plan were reinstated, showing redressability. | The Court received a counsel letter saying Forbes will continue to run in CD2 regardless, undermining redressability. | Not redressable now; Forbes lacks standing. |
| Have Representatives Wittman and Brat shown an injury in fact via evidence? | Wittman and Brat assert that alternative maps would add unfavorable Democratic voters and reduce reelection chances. | They produced no affidavits or record evidence quantifying or proving this alleged harm. | Allegation alone insufficient; no evidence of injury, so no standing. |
| Can an intervenor ‘‘step into the shoes’’ of the original party (the Commonwealth) for standing purposes? | Intervenors implicitly argue they may defend the plan and appeal. | precedent requires intervenors to independently satisfy Article III; they cannot rely on original party’s standing. | Intervenors must independently establish standing; they did not. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing requires injury in fact, causation, and redressability)
- Arizonans for Official English v. Arizona, 520 U.S. 43 (1997) (standing must be maintained throughout litigation; intervenor cannot assume original party’s standing)
- Hollingsworth v. Perry, 570 U.S. 693 (2013) (redressability requirement and limits on standing)
- Diamond v. Charles, 476 U.S. 54 (1986) (intervenor must independently satisfy Article III)
- Lewis v. Continental Bank Corp., 494 U.S. 472 (1990) (standing must be shown by the party invoking jurisdiction)