Anne Arundel County Republican Central Committee v. State Administrative Board of Election Laws

REPUB- ANNE ARUNDEL COUNTY COMMITTEE, CENTRAL

LICAN al., Plaintiffs,

et BOARD

The STATE ADMINISTRATIVE LAWS, al., et ELECTION

OF Defendants. Greiber, Jr., Office, Annap- R. Law John olis, Md., plaintiffs. for A. 91-3200. Civ. No. S Gen., Cannon, Court, Atty. Bal- Evelyn 0. Asst. United States District Zarnoch, timore, Md., Kathryn Robert A. D. Maryland. Gen., Rowe, Attys. Annapolis, Asst. M. Dec. 1991. Tate, Md., Praley, Lessans & James C. Md., Burnie, for defendants. Glen NIEMEYER, Judge, Before Circuit A. SMALKIN, FRANK Judge, District and KAUFMAN, Judge. Senior District MEMORANDUM OPINION I. INTRODUCTION plaintiffs in this case include citizens Mary- County, residing in Anne Arundel Re- land, as as well members of both party central publican and the Democratic County, Ma- of Anne Arundel committees They object ryland. approved by Mary-

redistricting plan Assembly on October land General They 1991, following the 1990 Census. jurisdiction alleging in this court filed suit 2284(a), pursuant to 28 U.S.C. §§ (4), 1343(3) and 42 U.S.C. § 1391(b). pursuant to 28 venue U.S.C. § 2284(a), a three- to 28 U.S.C. Pursuant court, Judge consisting judge of Circuit Niemeyer, Judge Frederic Paul District V. Smalkin, Judge District N. Senior Kaufman, A. was convened Order Frank Ervin, III, Judge of Chief Circuit Sam J. arguments plaintiffs’ mo- heard on the the de- preliminary injunction tion and/or fendants’ motion dismiss judgment, on the summary well as mer- agreement par- (by case of both its of the ties), open court December received The Court has considered exhibits hearing, parties’ well as the con- stipulated facts. has also Post-Argu- page plaintiffs' three sidered 395 pie average to this on and an Summary, peo- delivered Court deviation of four ment 16, pie. December 1991. having

This case been submitted to prolonged legislative There followed a law, of fact for determinations process fraught political with regional findings state our proceed now give-and-take, we at the end of which H.B. 10 of law. facts and conclusions passed 21, by was the Senate on October 22,1991. 1991 and the House on October II. FACTUAL BACKGROUND introduction, time of plan’s Since the population improved had Maryland was deter- deviation been population The 4,781,468. to a maximum of ten Census to be an aver- mined the 1990 age result, eight people.1 signed of 2.75 The bill was Maryland assigned was As a Repre- into law the Governor on October in the United States House of seats sentatives, quickly and this lawsuit followed. the same number as had Thus, ideal on the 1980 Census. based allege plaintiffs Maryland The contain congressional district would now Assembly good- General failed to make a 597,683.5 people. numerical equality faith effort to achieve May, Maryland among eight congressional In Governor new dis- tricts, fact, appointed Redistricting Advisory and, Com- 10 that H.B. discriminatory committee was to adopted mittee. The task with the intent to any boundary opportunity “deprive plaintiffs make recommendations on of an legislative congressional changes effectively participate necessary by rights shifts of their under process,” election districts made violation Maryland’s population, as indicated Article 2 of the United States Constitu- (Plaintiff’s 19.) Compl., plain- 1990 This the commit- The Census results. tion. did, plan August, allege represents tee in a issued in 1991. that H.B. 10 an tiffs also At the “gerrymander.” unconstitutional The this first committee soon abandoned plaintiffs’ argument is that heart of the plan, approved plan Sep- a second County, the State’s fourth Anne Arundel was, plan tember 1991. The first how- formerly part of populous county and most ever, the for a in and basis bill introduced District, Congressional the State’s Fourth passed by Maryland the Senate of as Sen- among by H.B. 10 four divided has been 25, 1991, September ate Bill 13 on the first “di- congressional thus separate day special of a session of the state’s Gen- luting” of the residents. the votes Assembly eral purpose convened for the redistricting. plan second committee’s passed by

was introduced and the House KARCHER III. UNDER ANALYSIS (“H.B.”) day, on that same as House Bill I, 2 of the United States the members of provides that Numerous amendments to these two Constitution cho plans offered, one, Representatives will be were the House of States,” by Delegate “by People several Bishop offered John J. and sen equal num designated popu- equal representation as H.B. had overall with Sanders, 376 Wesberry v. people. lation deviation of nine and an aver- bers 529-30, 11 1, 7-8, L.Ed.2d age population people. deviation 2.49 (1963). mandate Another This Constitutional plan, alternative H.B. had an 481 practicable one nearly as is population peo- overall “means that as deviation of eleven here, purposes 1. At trial and 1 for our the numeri- District +1 cal deviations in H.B. 10 were calculated based 0 District — upon Maryland Attorney interpre- General’s District 3 bill, tation of the as it should be read in order to District 4 +7 (See drafting correct a error. State’s Mem. of District +1 9-10; 85.) Stipulations Law at of Fact Plaintiffs District +5 reading do not take issue with this of the bill. — District population deviation in H.B. broken — District 8 district, by congressional down is as follows: reach unnecessary for this court to is to congressional in a election vote man’s addition, prong much as another’s.” Id. Con- second Karcher. worth as be are to that if the however, assert sequently, the defendants “precise reached, they mathemati- to achieve apportioned prong second of Karcher is Preisler, Kirkpatrick v. 394 equality.” cal thereunder. have met their burden 1225, 530-31, 1228-29, 526, 22 S.Ct. 89 to disagree We with defendants (1969). 519 L.Ed.2d is true prong it one of Karcher. While pro- most recent Court’s small, very that herein is the deviation concerning Article I’s “one nouncement are “that there specifically Karcher holds person, requirement found one vote” prac- no de variations could minimis which 725, Daggett, v. 462 U.S. 103 S.Ct. Karcher avoided, tically nonetheless which 2653, (1983). L.Ed.2d Karcher sets 77 133 I, 2 meet the standard of Art. without § two-part considering test for forth a Karcher, 734, justification.” at significance population legal of deviations added). (emphasis “Art. 103 at 2660 S.Ct. legislature’s apportionment of in a state I, popula- 2 limited permits ... § First, congressional districts. those chal- tion de- variations which are unavoidable alleged lenging redistricting plan a fail- spite good a effort achieve faith to absolute I, comply ure to with Art. bear the equality, justification proving population of that “the dif- burden at at 2658 shown.” Id. 103 S.Ct. among ferences districts could have been (quoting Kirkpatrick, 394 U.S. at altogether good- reduced or eliminated a (emphasis added)). S.Ct. at 1229 Justifica- equal popu- faith effort draw districts of tion, however, “belongs properly to more at at If lation.” Id. 2658. judicial inquiry of ... second level opponents redistricting plan a “can justify- which the bears State burden population establish that differences ing partic- differences with [statistical] were not the result of a [unavoidable nor] ularity.” 462 U.S. at 103 S.Ct. at Id. effort good-faith equality,” to achieve then shifts state. the burden In this case, has an aver- step, present H.B. 10 prove second state that age among Maryland’s eight con- significant “each variance variance between districts necessary legitimate gressional people, while achieve some 2.75 average 2.49 goal.” Id. at at The H.B. 22 has an 2658. variance justification people. (Stipulations paras. State’s for contested 77 and numerical Fact 84.) disparities particulari- plan must be made “with the existence of H.B. Given ty.” Id. at at 2663. numerical deviation from with smaller plaintiffs proved equality, absolute have Here, argue the defendants did not result H.B. 10’s deviations from equality deviation absolute numerical good effort to from an unavoidable faith present in H.B. 10 is too trivial to to a rise Thus, population equality. achieve we dis- constitutionally (State’s significant level. agree with defendants and hold Supp. Opp’n Mem. State’s forMot. case, even variations in this mathematical Inj. Prelim. and State’s Mot. to Dismiss small, though relatively plaintiffs enable 14-15.) Judgment and/or for Summ. at satisfy prong first and shift Karcher’s Claiming that the from variations absolute justifica- proving State the burden “unavoidable,” equality are the defendants prong tion two Karcher: under seemingly represents contend that H.B. 10 popula- required justify good-faith population showing effort to achieve flexible, depending on equality, satisfying Art. tion and the deviations deviations, impor- prong of making first thus size of er, Recently, acceptable three-judge departure from abso district no court in Illi there is nois, Elections, among congressional Hastert State Board equality lute numerical (N.D.Ill.1991), F.Supp. applied Karcher proposed redis will insulate a districts which redistricting 2§ an Art. case. scrutiny. tricting plan further that, court The Hastert concluded under Karch interests, resentation, of the State’s the consist- seniority, tance with its attendant ency with which as a whole Representatives.4 (See House interests, reflects those and the availabil- 23-28, Opp. Mem. in see also dissent- might substantial- ity of alternatives hereto, 38-41). opp. We conclude approxi- ly yet vindicate those interests justifications, these which the State population equality closely. more mate alleges properly are within the ambit of a jus- By necessity, whether deviations are legislature’s redistricting state latitude and requires case-by-case attention to tified designed legitimate goals, to achieve factors. these very sufficient to warrant small Karcher, 462 U.S. at 103 S.Ct. at 2664 among congression- numerical variance added). (emphasis al analysis districts seen here. The man- prong It is under Karcher’s second by Supreme applying dated Court cases relatively insignificant we now consider I, is, therefore, Art. 2 satisfied. § in this case. mathematical deviations We position dissent takes the degree justifi- note that the amount and analysis merely Karcher’s numerical cation which the State must establish I, beginning of the Art. 2 inquiry. As we § roughly equatable to the deviation itself. dissent, read the no state “classification” light, In that we consider aims people” (apparently “the a broader cate- Maryland which have caused it to voters) gory than product that is the of any particular congressional enact redis- constitutionally consideration is tricting plan before us. justified. Only classifications, “neutral” Karcher, provided In Justice Brennan barriers, geographic points such as natural guidance for the determination what or, compass, perhaps, historical mu- objectives might justify deviations boundaries, nicipal county and subdivision equality among from numerical the con- are to be considered as it gressional districts: apportions population for the House of Any consistently applied legis- number of short, Representatives. In the dissent policies might justify lative some vari- appear position to advance a ance, instance, including, making dis- would hold unconstitutional redistrict- compact, respecting municipal tricts ing plan any way affected that was boundaries, preserving prior the cores of “politi- considerations that could be labelled avoiding and contests between cal.” Representatives. long incumbent As as nondiscriminatory, criteria are ... Bren- Karcher’s footnote Justice legitimate objectives all these are that on Kirkpatrick’s nan noted that and Karch- proper showing justify could minor population equality ’s mandate for er population deviations. among congressional districts alone would (citations omitted). prevent do “little is known as Id. what gerrymandering.” 462 U.S. at presented and in Both the evidence course, nothing prevents S.Ct. 2660. Of argument, oral the State has set forth sev- plaintiff/opponents redistricting of a consistent, convincing, legitimate eral challenging plan on consti- justifications for the numerical deviations grounds tutional either inside or outside of (1) keep- within H.B. 10.3 These include: I, prohibited Art. 2. Any classification ing major regions § intact the three that sur- among people” of or distinction “the is still (specifically, round center of the state cognizable, example, under the Shore, Southern, rubric the Eastern and Western (2) voting of the First and Fourteenth Amendments. Maryland), creating minority Bandemer, district, (3) See, recognizing rep- e.g., Davis v. 478 U.S. incumbent Weiser, 783, 791, Court, Leading 3. See The 4. See White v. 1982 Term — Cases, (1983), 2348, 2352, suggesting (1972). 97 Harv.L.Rev. 37 L.Ed.2d 335 justifications that Karcher teaches that such flexibly by to be considered the courts. (1986).5 willing legislative poli- to state 92 L.Ed.2d defer cies, as are consistent with Art. so provided protections within § norms, they require if Further, constitutional even protec- speak for themselves. population in the small differences and Fourteenth provided by the First tions congressional districts. Amendments, many other as well Constitution, provide parts of our Federal Karcher, 462 U.S. at 103 S.Ct. at person, backstop to the “one one vote” added). (emphasis Moreover, in Art. requirement case, Mary- In this this Court defers to recognized footnote 6 of Justice Brennan evidence, legislature. The as the land’s statutory state constitutional states, As- dissent shows General backstop- a similar provisions also serve alia, give Congress- sembly, inter aimed to ping purpose. high Hoyer, congressman man with rank- importance in the federal House of taking 2 prohibits The idea that Art. seat,” Representatives, a “safe flatly into account is any “political” factors majority population in an area of black language in contradicted Karcher George’s Montgomery counties Prince itself: representative with a chance to choose a apportion- that We have never denied person to run requiring without that political process, a or that ment is against strong incumbent such as Con- legitimate sec- legislatures pursue could Hoyer, certain gressman and to objec- as those ondary objectives as opportunities Congresswoman Bentley good-faith consistent with tives were Congressman Dissenting Opp. Cardin. population equality at effort to achieve 18-21. The reelection of incumbents as at the same time. specifically by such was not listed Justice at 103 S.Ct. at 2662. Nor is U.S. example Brennan in as an Karcher unique to such a discussion Karcher. legislative justification affirmative suffi- long recognized the Supreme Court has prong, cient to meet Karcher’s second appropriateness considerations though recognized in v. White Weiser. redistricting process. In within the White majority is the of a Neither establishment Weiser, at at v. U.S. specifically district listed black beginning, the Court noted that “from the “preserving strength of racial mi- recognized reapportionment that we have Karcher, 462 nority groups” is discussed. primarily legislative a matter for considera- aims, at 103 S.Ct. at 2664. These U.S. determination____” Indeed, the tion and however, clearly within Karcher’s am- recognized and not dis- Court there “d[id] Brennan there conclud- While Justice bit. parage” policy pro- the state defendants’ finding ed that the District Court’s of a moting: lack of causal connection racial between “ ‘constituency-representative rela- voting redistricting plan and the aims tions,’ frankly maintain- policy aimed at erroneous,” “clearly issue was not id. ing existing relationships incum- between 103 S.Ct. at the sense of Karch- congressmen and their constituents bent if, here, suggests strongly er such preserving seniority the mem- exist, a causal connection does such aims delegation bers of State’s have appropriate sec- can constitute an Karcher House achieved the United States ond-prong basis. Representatives.” note that the “neutral criteria” We also Surely, Id. at 93 S.Ct. at 2352. such redistrieting by the called for dissent would language recognize does not command way in no ensure maintenance of the terri- I, 2 “political” in Art. classifications County, integrity torial of Anne Arundel redistricting. during cannot be made brought in the which is what on this suit clear, Rather, place. adoption of the dis- As Justice Brennan has made first subject Supreme position potentially sent’s Court is post 5. See discussion at 399.

every congressional legislature intentionally district in the United draws lines “to af scrutiny. to novel constitutional political groups States ford in various districts an Furthermore, mandate that a opportunity enhanced legislators to elect regard merely to reapportion with “neutral their choice respond ... ‘we must ... (except for the dictates of the criteria” claims ... acceptable even if [the] Voting Rights Act and the Fifteenth populationwise, the ... was invidious Amendment) legislature, give is to in ly discriminatory ‘political because a fair ” Indeed, practice, guidance no at all. principle’ ness Davis, was followed.’ court, virtually guarantees that a federal 124-25, U.S. at 106 S.Ct. at (quoting judicial receivership, will ultimate- sort Gaffney Cummings, 751- redistricting process ly conduct the Su- —a 2321, 2330-31, 37 L.Ed.2d 298 consistently recognized preme Court has (emphasis Thus, in original)). Davis, political.6 reached question whether, of. political party where one IV. OTHER CONSTITUTIONAL makes a claim of during discrimination re CONSIDERATIONS districting, the justiciable. issue is rep that H.B. Plaintiffs also contend In the Court, case before this plain- “gerryman resents an unconstitutional represent tiffs both the Anne Arundel der,” Maryland and therefore Gen Democratic and Republican parties. The Assembly against eral has discriminated type partisan discrimination treated them, Equal violation Protection apparently Davis has not occurred here. Clause of the Fourteenth Amendment. Indeed, plaintiffs contend that the dis- support position, plaintiffs of their cite crimination suffer as a result of Bandemer, 109, 106 Davis v. H.B. 10 stems from the effect that (1986), 92 L.Ed.2d 85 in which the County division Anne Arundel has on gerrymandering politi Court held that plaintiffs’ ability “effectively partic- purposes justiciable Equal cal under the ipate [group] thereby as a influence Protection Clause of the Fourteenth process the elective to secure atten- Amendment.7 (Plaintiffs’ winning tion of the candidate.” plaintiffs presented What have in this Opp. Mem. in to State Defendants’ Mot. to political gerryman- instance is not a case of Judg. Dismiss And/Or Mot. for Sum. dering in as seen Davis. The in 35.) essence, therefore, plaintiffs holding limited its political Davis —that they, contend County as Anne Arundel gerrymanders justiciable in- cases —to voters, constitutionally have form of some volving partisan bias. “[E]ach significant community interest which will group in a State should have the same goes be diluted if H.B. 10 into effect.8 representatives chance to elect of its choice political group.” Davis, other Assuming justiciability reaching merits,9 keep U.S. at 106 S.Ct. at 2806. Where a federal this court must during Maryland County only County 6. We note that Senate Pro- 8. Anne Arunel is not 21, 1991, ceedings following by Montgomery, on October 10. Others divided HB include colloquy place: George's, took Howard and Prince all divided be- City tween two and Baltimore mightily, PRESIDENT MILLER: We labored County, among Baltimore each divided three majority my- leader and the chairman and districts. self, and we made a conscious decision that it adopt was better that we this with these establishing justiciability standard for 9. modifications than let a nonelected federal Carr, well settled. See Baker v. judge, non-political person map draw a for us. (1961). 7 L.Ed.2d 663 The court help VOICE: God us. (1) three-part Baker elucidated a test: issue Pls.Ex. 17 at 80-81. properly coequal must not be more decided issue, (2) government, part 7. As a threshold we note that in Davis the there must be no risk of upon foreign Court was called to address a or domestic disturbance or embarrass- ment, challenge (3) partisan redistricting judicially there must be discerni- legislature, congressional manageable Indiana not to redis- which the ble and standards tricting. case can be decided. Id. at 82 S.Ct. at 714. different counties in Mary- and cul-de-sacs of 23 mind that the voice of people for each match two white through the order to directly heard land is most black, republi- for each or two democrats Maryland. While the Assembly of General can, advancing the purpose people,” as the dissent interests of “the class win chances that favored “people” emphasizes, predominate, diluting the an election while vote even Maryland cannot the State 1789, prac- unfavored class. done in they if could have so a state- individually via tically heard be Dissenting Op. do not We have The most meeting the whole. wide town specific example us and there- before “people” is of action direct channel it.11 If the territorial of fore do not reach representatives in both via their elected County is a Anne Arundel classification—a branch Maryland’s houses doubt,12 proposition do not —a we but also structure, as is governmental of our total classifications, it, like all have reach— court, scrutinizing A this Court. federal fact, if a reasonable even no sus- basis redistricting plan, should race, religion, pect criterion such as sex reject- long and hard about therefore think the like is involved. justifications reasons—the —of Underpinning appears the dissent to be legislature.10 that, independent proposition of Karch- consider and It is in such context we person-one er and of numerical “one challenge reject plaintiffs’ to what doctrine, political gerrymandering vote” gerrymandering. as unconstitutional label egregiously can so unbearable that it not, suggests, do as the dissent believe We pass cannot federal constitutional muster. gerryman- upon are no limits that there not, case, ques- We do and need not dering. We do hold position. See, e.g., tion that conceding correct in (Stevens, J., at 2665 U.S. at concurring); Polsby D. D. interpretation under its Daniel & Robert Popper, Compact- a district The Third would not be violated Criterion: alleys through Safeguard Against line to snake ness as a Procedural drawn borough. May light you prongs upon second and third of this test God’s curse all: Both the may your open give pause be as us in this case. houses and common to your Officers as wifes [sic] all Excise me, daughters your were to when I stood for analy- keeping 10. with the dissent’s historical sis, corporation. gerrymandering scoundrel that was not con- we note Yours, etc., country. ceived out of the blue in this The Anthony Henley borough” "rotten that had few electors or —one Norwich, long concept John Julius Christmas Crackers 93 voters —was a similar and one that (1986). borough plagued English. A rotten give person boroughs used to a seat in Parliament to a Rotten and other electoral anoma- reward, Parliament, political party by judi- wished to albeit whom lies were eliminated not decree, very person. often a able Act of See cial Reform 1832. Holdsworth, generally History William S. A boroughs, in which the member of Pocket (1952). English Law 239-59 seat, similarly purchase his Parliament could repre- diluted the vote of the whom he political gerrymandering 11. What constitutes Representative attitude that such sented. beyond going pale so far as to be unac- politicians had electorate towards their is ceptable setting in our constitutional federal following: hard to But as Justice Stewart once define. following by Anthony The letter was written pornography, wrote about most of us “know it Henley, Southamp- Member Parliament Ohio, see U.S. when we it.” See Jacobellis constituents who ton to his from 184, 197, 12 L.Ed.2d protested had to him about the Excise Bill: J., (1964) (Stewart, concurring). We can well Gentlemen, afford, Brennan, writing as Justice in Karcher yours surprised by your I received and am mind, leaving seems to have had to another troubling insolence in me about the Excise. day and to another case the task of know, know, very You what well I gerrymandering federal constitutional limits to know, you bought you. perhaps And I what districting. congressional know, you selling your- don’t are now think I Else; Somebody what selves to and I know know, you buying supra do not that I am another 12. See at 399. Gerrymandering, they might Partisan 9 Yale Law & al districts in which find them- (1991). They join PoLRev. 301 As Justice Brennan selves. pre-existing free to noted, committees, principle popula- political ones, has federal form or new use “[a] equality prevent any tion disposal does State whatever other means are at their taking steps gerryman- opinions from inhibit to influence the congres- their dering, good-faith representatives. so as a effort is sional population equality made to achieve as plaintiffs To the extent that any of —and at 734 n. well.” 103 their fellow Anne Arundel Countians—are S.Ct. at 2660 n. 6. legitimately distressed H.B. suggesting polit-

The political setback, dissent have suffered a but not a appro- ical considerations which constitute violation of their federal constitutional priate justifications rights, through under Karcher’s sec- people” of “the action I, prong expressed directly ond somehow violate Art. or repre- elected § mandates, people” other federal constitutional sentatives of “the Maryland. any approach, both. The answer to such upon principles Based articulated however, is that the Court would herein the context of the evidence hardly put stamp approval have on a presented case, in this this Court concludes justification under Karcher’s second defendants, merits, the State on the prong, justification if such constitu- were judgment are entitled to in their favor. tionally any invalid for other reason. In Accordingly, judgment will be entered event, any prevented a federal court is not favor, by their separate order. granting any relief under available provision gerry- NIEMEYER, federal constitutional if Judge, Circuit dissenting: it, mandering and if matter violates Maryland legislature, using data justiciable. point carving Anne political party registrations, about voters’ County pieces Arundel into four —while habits, past voting race, their and their perhaps enough eyebrows to raise —does depict drew district lines to provi- not violate federal constitutional gerrymander the classic attempt sion, including the mandate of Art. control the congression- outcome of future give “peo- full effect to the voice of the al elections. Because the use of such clas- ple.” in drawing sifications district lines favors plaintiffs necessity Furthermore have not one class and of dilutes the vote another, any discriminatory shown represented vote dilution. of are not Davis, directly equally, required by See 478 U.S. at Art. Nothing plaintiffs present- have of the United States Constitution. ed to this Court indicates that their vote I concur with the conclusion reached necessarily any will in powerful any be less majority requirements the that the of of the four districts in which 725, 103 Daggett, Karcher v. 462 U.S. they Nothing prevents will now reside. the 2653, (1983), 77 L.Ed.2d 133 have been sat plaintiffs joining organiza- from the local eight isfied H.B. 10 in that each of the political parties tions of the of their choice has, congressional districts created it previ- having power they whatever had equal popula practical purposes, for all an ously political process. to influence the necessary tion. I would not even find it Thus, arguendo that assuming pass step step one to two of the issue, present justiciable plaintiffs the analysis. requires Step Karcher one a de showing fail to make a Davis of vote dilu- good of effort termination whether faith tion. the was made to divide state into districts if equal population. Only

Plaintiffs’ claim also fails under a First in there is a analysis. Nothing “significant Amendment H.B. variance” about between reached, any proscribed way plain- step requires 10 affects in the two be which ability participate justify in the Id. at tiffs’ that state variance. In any Maryland congression- debate in of the 103 S.Ct. at 2658. this case 402 concession, difficulty making that

greatest from the “ideal” district of variance policy or considera- “in persons. gerrymandering is seven No our federal because tion, shifting my judgment, in served setting define,” is is hard to constitutional persons or from one three four district “most of majority concludes that us ‘know ” failing another or needs to be advanced for (quoting we it’ v. it when see Jacobellis to shift them. Ohio, 378 84 S.Ct. U.S. J., (1964) (Stewart, L.Ed.2d submit, failing, major respectfully concurring) (attempting pornogra- to define opinion acceptance its majority is acknowledging that our phy). Without position by the that advanced State founding duplicat- fathers intended to avoid requirements are sat- once of Karcher words, isfied, boroughs” problem Lon- analysis ends. In other the “rotten majority don, legislatures, holds that Karcher establishes by relying not on state equality per se rule that once numbers adopting Article I to direct but achieved, analysis is appropri- no further equal representation people, see requirements ate to determine whether the Debates in the Federal Convention of met, I, Article have if the been even § Reported 1787 as James Madison lines state’s motive district (James & E. Bradford McClellan Melvin found to invidious and the effect were eds., 1989) Elliot’s [hereinafter Debates] total of its delineation were found be the (statement Wilson); id. 207-08 of James recognized dilution the vote of a class (statement Madison), majority of James or position voters. That leads to recognizes prohibition against gerry- politically or racially conclusion that drawn mandering, subjectively it but when lines, gerrymandered, however cannot vio- defines as such. late con- The State thus defending on the contention argument ceded at under its inter- oral are free to draw district states pretation, Article not be violat- fit, way they so lines see by a ed district line drawn to snake each district includes the same number through alleys and cul-de-sacs of recognize fails people, different counties order to match two centers, reapportionment on a case black, for each demo- white two Maryland legislature, on effec- republican, purpose crats each for the people’s tuation of the election of their advancing the chances that the favored diluting Representatives Congress. class distinc- would win election while the vote of the class. and critical. unfavored tion both clear “There congres- fundamental differences between appropriately While Karcher addresses districting under Art. I and sional the Wes- created by inequali- vote dilution numerical hand, and, berry line of cases on the one among ties it was never intended other, legislative reapportion- other hold- overrule the v. Gaffney Cummings, ments.” ings, Sanders, Wesberry such as 735, 741-42, 2325-26, (1964), 11 L.Ed.2d 481 (1973). Despite arguments by L.Ed.2d 298 recognize prohibi- Constitution’s contrary, the State to state’s role against by any tion vote dilution classifica- Representatives House of constituting a require representation tion and by law the limited federal to people equal. be direct and de- Karcher “time, place and manner” of and elections only cided the issue in of when variance sending Representatives Congress to to population among justi- districts can be districts “direct and majority fied. limited The extends this representation equal” people, the all of holding Article requires to conclude that I of accomplish purpose them. To nothing no clas- population equality. more than people But in sification to response dissenting opinion, to this of can be made legislature’s preference the majority do be- advance the state concedes “we not ... another, upon gerryman- lieve there are no limits for one class to the detriment of dering” imposed by clearly I. Recognizing attempt Article the state not to legislative granted elec- Powers herein shall be the outcome of

dictate Congress States, in a vested of the United tions. shall consist of a which Senate House shows, In this case record Representatives. Repre- of The House of concedes, of con- the delineation State be composed sentatives shall of Members largely on gressional was based every People second chosen Year of they of how voters classifications States.”). the several As described the interests of in order to advance vote James Madison The Federalist No. Representatives, assure existing to some Representatives, House of like that [t]he anoth- expense of a “safe seat” at the one of one branch least of all the State purposes of er, political to serve the Legislatures, immediately by is elected The drawing the lines. those involved great body of people. The Sen- concedes, shows, and the also record ate, present Congress, like the and the to cre- made that racial classifications were Maryland, appoint- of Senate derives candidate a district which a black ate indirectly people. ment from the and to the black voters would win remove intend- of that district from the “safe seat” important An distinction is thus deliberate- The result Congressman. ed for another ly people. made and the between states drawing impermissible lines using such framers The debated whether the gerrymander depicted is classifications political agents act as for the states should map on attached. selecting Congress, people members prohibition against A I classifi- instead deserve and people or whether cations that are the voters based on how require representation direct in the federal vote, expected and can be to for the voted legislature. “While those wanted both who steering purpose of of an elec- yielded the outcome represent people to had houses tion, not, majority suggests, Senate, does as the yielded on the not had recognize to inher- political process fail Representatives. Sam- House of William legislative every Any legislative ent in up act. ‘in ... had summed it well: uel Johnson “political” is repre- act to the extent each people, ought to be one branch ” legislator personal votes on sented; other, the basis of in the the States.’ Wes- philosophy, to constituency, and the desire (quot- at 533 berry, 376 U.S. That be reelected. is far different than a ing 3 Records Federal Conven- (Farrand 1911) law enacted which is (empha- ed. tion of1787 designed manipulate an election outcome original)). Argument centered not sis per- of fear that appropriate out neutral criteria would only upon the method of ascer- mit the taining distributing power vote otherwise. relative states, representation among the but drawing purposefully Because lines that also, importantly, upon ap- perhaps political necessity one advance interest of assuring that propriate structure for the opposing dilutes interest and therefore legislatures, and not the state people, I, 2, Constitution, I violates Article meaningful representation in the achieve permit Representa- would not an election of legislative body. federal Congress proceed on the basis of tives to H.B. 10. of that Article which the outcome debate, clearly the House establishes a means for Representatives power ensuring legislative of the United distribution power corresponds federal level legislature, on the States vested a bicameral states, which, populations body Represent- the relative one the House repre- atives, body intended also as the that is intended represent other, states, people and not the states. See the the sent the of the several (“Mr. intended, Madison con- Senate, act as a Debates at 75 originally as to Elliot’s least of election of representative body for states them- sidered an one branch the Const, I, (“All by Legislature people the immediate- art. the selves. See §§ (statement Elseworth). free Mr. Colonel Ma- principle of of ly, as a clear [Govern- proper Virginia agreed: power under son “A this mode from and that ment] advantage regulations the additional qualifications danger- had alter the would be a representatives, as well securing as power Legislature.” better ous in the hands of the agency the avoiding great too Id.; (“A gradual abridg- see at 385 also id. one”) in the State Governments General right suffrage] ment of has been [the added); (reporting (emphasis id. at 39-45 the mode in which Aristocracies have been delegates popular disfavored some forms.”) popular built on the ruins of legisla- first branch of the election of the (statement Madison). end, Mr. the it ture, others, including while Mr. Mason and right suffrage was determined that the argued strongly Mr. Wilson for an election ultimately must state be left to neither nor larger of the branch of by the legislatures, people. federal to the people); Wesberry, the 376 U.S. at ability Thus to vote for members of (“The Representa- S.Ct. at 533 House of Representatives House of tied to the was tives, agreed, repre- Convention was to existing qualifications, by state fixed con- individuals, people sent the and on a stitutions, body for the most numerous complete equality____”). basis of Const, legislatures. the state See U.S. art. The deliberate and careful distinction As cl. 1. noted The Federalist Representatives Madison), thus made in the House (James No. 52 representation for people of the and not the provision by made the convention [t]he legislatures state preserved throughout therefore, appears lay best that be the provisions House of option. within It be satisfac- their Representatives regulating its mem- State; every tory to because is con- bership. question Even the of who voted already formable to standard estab- Representa- for of the members House of may by lished be established or which tives question, was not ultimate so safe the State itself. It will be to the represent- as whoever entitled was to vote States; because, being by United fixed people. Reasoning principle ed the from Constitutions, State it is altera- governments already state had Governments, by ble State and it been constituted and from a feared cannot be voting privileges desire to harmonize in the part States will of their Consti- alter given qualifications so States that voter tutions, abridge a manner as to such for be similar state and federal elec- rights secured to them the Feder- tions, carefully the founders bypassed al Constitution. legislatures right state and tied vote added). (emphasis provisions in each state constitution setting time, Only place and man- providing voting rights largest legis- for its expressly ner of elections did the framers lative house. Some were concerned with legislatures, defer to then problems might arise from the govern- with the reservation to the federal qualifications of differing establishment power ment of issue. Arti- ultimate for federal and state elections. See Elli- Times, provides: cle “The cl. (“It ot’s very Debates at would be hard holding Places and Manner of Elections for disagreeable & persons the same at the Representatives, pre- shall time, Senators and same vote representatives Legislature scribed in each State Legislature and to be excluded thereof; Congress time a vote for but the those in the [National] (statement Legislature.”) Regulations, Wilson). Law make or alter such of Mr. delegates except But chusing most Sena- primarily put- feared to the Places of ting power qualifications modify elector tors.” at 403 See also Elliot’s Debates (“[T]he ought hands of either Legislatures the state or States legislature. federal right right suffrage regu- “The not to have the uncontrolled point, was a strongly guarded tender lating places the times & manner of hold- elections____ by most State impossible Constitutions.” Id. at It might state in policy fashioning all the that made relief foresee abuses be con- [in (statement of discretionary power.”) gressional redistricting the only of where case] Madison); (“If power at 404 be Mr. id. the policy is consistent with constitutional Legislature, given to the norms itself legal [National] and is not vulnerable to right of of the of judging their returns challenge.”). frustrated.”) (state- their members be When a state divides itself into King). ment of Mr. preserve representa- the must the division that question There can be no the issue people, directly tion of the and without determining selecting of the method of any by agency interference of the state Representatives of the of members House legislature. representation The direct of uniquely exclusively ques- and a federal is inherently the people requires that all the tion, only given limited role with people represented, of a state be and to Yarbrough, Ex 110 U.S. states. See Parte goal accomplish representation that the (1884) 28 L.Ed. 274 theme, repre- This equal. be (“It not true that electors for mem- is ... people the House sentation of in the of Congress right of their to vote to bers owe Representatives equal, must be and direct law____”); United v. the States Clas- recurring was and consistent in the debates 1031, 1037, sic, 313 U.S. 61 S.Ct. framers, adequately of the (“While, (1941) 85 L.Ed. a loose early by Story: Justice summarized sense, right representatives for the to vote accordingly find, in the We that section Congress spoken is sometimes of as a consideration, repre- of under the house states, right derived from the this state- required composed is of sentatives ment is true in the sense that representatives people by chosen of Constitution, states are authorized too, choice, states. The several provided legislate subject on the them; immediately by so that be made I____”)(citations omitted). 2 of Art. § direct; di- power influence finally Constitution summarizes the su- rect; responsibility direct. If and the premacy pro- of federal role when it agency had been intermediate Congress that each vides House is re- through such as choice adopted, sponsible judging elections college, personag- byor official electoral qualifications of its members. U.S. See es, qualified specially select and Const, I, exception art. And no cl. 1. § vice, obvious, it is pro hac functionaries size, location, determining is made representa- dependence configuration dis- people, responsi- upon the and the tives tricts. These to the principle must conform them, far would have been less bility to representation direct felt, far more obstructed. required I.

people, as in Article Joseph Story, on the Con- Commentaries requirement Article makes no (1833) the United States stitution Congress represent members added). analysis In a (emphasis detailed state, within a so allo- number Supreme reached the given to a cated state determined Reciting Wesberry. same conclusion population. Congress many years did for debates, Court stated that actively regulate congression- mandate and Representatives “the was meant House districting, it has al but since 1929 assumed malapportionment then to be free of regard. a less active role Wes- See legislatures” existing in some 42-44, berry, 376 U.S. 547-49 at power Congress’ supervisory un- and that (Harlan, J., dissenting). This leaves to 4, was “to vindi- role, der Article intended always states service right repre- people’s equality cate government and the the federal Wesberry, 376 sentation.” accordance with the federal Constitution. pro- Equal Weiser, 783, 797, representation S.Ct. at 534. White Cf. equal weight (1973)(“Of people a vides to the vote 37 L.Ed.2d Thus, course, should are located. District Court defer wherever 406 said, what said, equal, are when a one must ask constitu- “[ejections This citizens,

given of the part permissible one are available tionally number of means state, many representatives, as duty choose as out their carrying states citizens, are same number of chosen designate representative districts which ef- 17, any part other of the state.” Id. right of their citizens to elect a fectuate 84 a lecture Justice (quoting S.Ct. at 535 of delegation starting House. Wilson, actively in participated James who that point proposition must be the state (cid:127) Convention). princi the Constitutional legislatures, consequently the district ple has as follows: “The been summarized draw, aim at mini- lines that should rep principle equal basic of constitutional on the mizing states’ effect outcome of 2 for resentation established Art. the election. The division must not focus eliminates, congressional so far as bids and a of particular on classification citizens a concerned, representation considera way abridges” “unnecessarily their any population.” tion of factor other than 17-18, Wesberry, vote. 376 U.S. at 84 See Missouri, Secretary Preisler v. of of (“Our 535 no S.Ct. at Constitution leaves (W.D.Mo.1966)(deci 953, 973 F.Supp. people in way room classification of court), judge Kirkpat sion of three aff'd abridges unnecessarily right.”). this Preisler, rick v. 385 U.S. 87 S.Ct. dividing It is thus observed that in its citi- (1967); v. L.Ed.2d 511 Ban Davis cf. geographical zens into a state demer, rich, identify poor, may not voters as demo- (1986) (holding L.Ed.2d 85 that the Four cratic, republican, persons who voted for guarantees teenth Amendment candidate, persons expected one or who are State, in itself dividing geographical into to vote another. For do so would districts, may voting identify of voters arbitrary constitute “the deliberate and dis- political one party with the and ef intent popula- tortion of district boundaries and fect of diluting party). the vote of another partisan personal pur- tions for or legitimately disputed, It cannot be there- poses” gerry- classic definition —the fore, that under structure of the Con- Preisler, Kirkpatrick mander. See stitution, of Representatives the House equal rep- established to direct and J., (1969)(Fortas, concurring). L.Ed.2d 519 people any resentation of the without inter- only interpose Not do such classifications fering agency part on of the states. state, improper by the interference an The states’ role is limited to agency clearly that was intended to be time, place and manner of elections in the excluded determination House (subject supervision) pro- federal members, insidiously, recogni- more viding the people with districts assure peo- one tion and enhancement of class of equal representation. direct and The crite- ple necessarily repre- or voters dilutes the ria to applied be in dis- states classes sentation vote other not fa- charging responsibility can based vored. policies secure the direct and we When eliminate from consideration equal representation people —not or classification legislators, groups, perceived interest purpose favoring voters for the one interests of the state as a whole—in order another, diluting we class and are left with representation to assure without vote dilu- creating criteria for in a manner tion for particular Accordingly, interest. that is “neutral.” 462 U.S. at must be right conceded that the Cf. (“[That] S.Ct. at 2674 directly neutral deci- Representa- elect their developed tives to sionmakers on the larger House of federal basis along nothing if neutral criteria” with other means the Constitu- factors, tion strong does not results in attachment of “a manip- forbid states from ulating the boundaries of presumption validity redistricting dis- [to (Stevens, tricts in attempts plan].”) J., concurring). to influence the outcome While people’s congressional numerous, possibilities elections. for whatev- exist, practical Kirkpatrick histori- lished er reasons Karcher geological strictly prevent cal choice has been structures enforced to vote dilution boundaries, including long-standing population, caused in variances so too municipal county state subdivision prohibition against must the voter classifi- recognized It from boundaries. must be cations. the these are not start that even criteria requires The appli- Fifteenth Amendment absolutely neutral. See Davis v. Bandem- allowing principle of a cation second limited er, 129, (argu- 106 S.Ct. 478 U.S. at at 2808 Compro- The Great consideration of race. ing improper political in state intent purpose mise slaves for the classified easily redistrieting proved be should be- representation measuring relative reality districting is that inevi- cause “[t]he Const., 2, the States. art. cl. See U.S. § to tably has and is intended have substan- during pro- 3. Even the debates this was consequences” tial political (quoting Gaff- shortly blematic thereafter Madison 2331)). ney, 412 U.S. at S.Ct. at awkwardly it. sought to defend See But conclude that the nonexistence of Madison). (James Federalist No. 54 districting totally neutral criteria means War, adoption American Civil of the placed may any limits be on at- no Amendments, post-war including particu- to alter the tempt the States outcome Amendment, larly the Fifteenth and the people’s representatives election of Voting Rights enactment of the Act of concluding Congress is tantamount (1988), 42 U.S.C. have at- § I debates at the the Article Constitu- tempted to that error. Today correct it is meaning. had no tional Convention that, drawing the law of the land before compactness contiguity Concepts of lines, any right any that “the we ensure geographical to established restrictions citizen of the United States vote [is served, have since the earliest de features abridged neither nor on account of denied] into congression to divide the states cisions (1988); race or color.” 42 U.S.C. § political al as constraints on the Gingles, see 478 U.S. Thornburg legislatures against

will usur of state (1986). This 92 L.Ed.2d pation people’s See, vote. Act e.g., of the principle, along with strict second 25, 1842, (1842); of June 5 Stat. 491 equality populations re- of district also Karcher, 756, 103 462 U.S. at S.Ct. at 2673 necessary is a quired Article (“To extent, geographical compact some redistricting plan. overlay Natural- independent values; ness serves it facili require- ly, one-person, one-vote strict organization, political tates electoral cam applied can after district- ment paigning, representation.”) and constituent process using neutral criteria. ing begun (Stevens, J., concurring); id. at Otherwise, required precision (arguing that departure S.Ct. at 2683 lead to an apportionment limitation would existing geographical and bound affecting justification the out- apparent potential unlimited aries leads to for delib people’s come of the election. See Wells v. J., (White, partisan gerrymandering) erate 542, 551, Rockefeller, 89 S.Ct. dissenting). may While other constraints (contend- 1234, 1240, (1969) 22 L.Ed.2d 535 neutral,” prove “more restric to be these ing equality that a “of absolute standard said tions at least be to establish a ‘gerrymandering’ perfectly compatible with neutrality” below “floor J., sort”) (Harlan, dissenting). worst states cannot venture. Finally, any legislative enactment state principle district As a first congressional district lines draws boundaries, then, legislature may a state Equal subject, theory, Protection of voters or of the make no classification As Fourteenth Amendment. Clause (except possibly comply with however, matter, practical issue need Voting Amendment and the Fifteenth congressional redistrict- Rights noted), not be reached Act as hereafter instead ing compliance cases rely on available neutral criteria. because of Article to numerosity requirement requirement with the Just as the estab- representation peo- remaining five dis- equal direct and state’s necessarily question neutrality call into ple drawing pro- district lines tricts plan. predomi- people equal protection District which lies vides Moreover, satisfy- nantly George’s County, laws. the standard for Prince wanders county Montgomery I is a stricter one than that for across the line into 159,000 satisfying County, plucks the Fourteenth Amendment. from which it about 732-33, persons. District See which was referred Delegates at 2659-60. floor of House of amoeba,” “splitting in and out of darts summary, comply In with the Consti- Baltimore, City way it as weaves its law, congression- tution and other a federal through three other counties as well. Dis- redistricting plan al a state undertaken Mary- encompasses trict all of legislature begin with neutral crite- shore, leaps land’s eastern across the Ches- ria, city such as natural barriers Bay apeake County, into Anne Arundel lines, county and then be modified bay rather than follow the contour of the necessary extent to achieve numerical and the state’s northern border into Har- equality population within districts. County. way ford And District finds its Finally, the state must check to ensure that County Patapsco from Baltimore across the resulting comply the Fif- with County pick up River into Anne Arundel applicable teenth Amendment and the man- 45,000 vicinity. residents of Dundalk and Voting Rights dates of the Act. evidence this case substantiates II suspicion these districts were interests, drawn to a fact serve Given the conclusion that Article I re- argument. conceded the State at oral quires simple equiva- more than numerical portion overriding In the northern con- congressional districts, lence of go I would legislature cern of to accom- the state was beyond finding the fact efforts of the ma- Representative modate the desires of U.S. jority to consider whether the State used Bentley. privately publicly She both other than neutral devising criteria in objected plan to the initial of the Gover- plan Maryland eight to divide into congres- Advisory nor’s Committee and threatened so, doing sional In appropri- districts. it is challenge plan it in court because the map ate to look first at the which is the Bentley’s would have eliminated 1990 dis- product final decisionmaking the State’s paired against Represent- trict and her U.S. process. plan compact If the forms Maryland’s ative Gilchrist in District 1 on contiguous largely districts which follow addition, Representative eastern shore. In county, municipal, geograph- or identifiable Bentley Pica, informed state Senator head boundaries, ic then presume, the court can of the Maryland redistricting Senate com- absent contrary, direct evidence to the mittee, her desire for “a district she districting plan is neutral. On the oth- believed she could win the next elec- hand, er plan [in] where the final includes Ultimately got tion.” she she what want- shapes that look more like characters on a ed. Saturday morning program television than compact voting the court should Miller, State Senator who served on both plan question

look behind the how the Advisory the Governor’s Committee and legislature at arrived its final decision. committee, the final thought conference A look at map depicting particularly the redistrict- that “it was unfair to Con- ing plan suggests gresswoman did apply Bentley Helen to ask her to preserving neutral criteria in Shore, intact running consider on the Eastern es- southern, eastern regions pecially and western when her port forte was the Maryland. The Baltimore, district lines in Dundalk, these three which is Essex regions county geo- follow boundaries and region.” In redistrictihg plan, the final graphic state, lines. In the center of the Bentley’s jumps Patapsco District however, shapes convoluted of the River Anne County into Arundel to secure addition, rather in the district. While this have sur- port

for her the area. legal challenge, plan eastern vived increas- District 1 from the than extend probability es the the State could Bentley’s dis- Representative into shore powerful one of its senior and lose most trict, portion legislators attached congressmen. lib- County shore Arundel to the eastern Anne erty possibility to decide los- Bay Bridge. by way Chesapeake Congressman Hoyer was detrimental expla- apparent geographic are no There to the entire state. This would also configuration unique nations have made more difficult for minori- Interestingly, ac- presented by District 3. ty to elected that district. director, Bentley’s cording legislative Overriding public expressed desires por- Representative Cardin wanted meeting Hyattsville, legislators thus County, City, Baltimore tions of Baltimore county carved the districts. The into two County, of the four three and Howard district, minority through District winds 3 now through which District counties George’s County (conveniently Prince Furthermore, uneven bound- snakes. avoiding Hoyer) the residence of Mr. Repre- this district and that ary between Montgomery into southeastern County. carefully Bentley apparently was sentative wishes, Hoyer’s Consonant with District 5 between the two drawn to allocate of Prince George’s includes remainder including two particular politicians, County Maryland. and all of Southern senators, delegate a United a state Ironically, questioned when whether a attorney. States white-majority district” should “new division A cause curious third Hoyer, seventy per created for cent of the was clear desire center the State's George’s County polled Prince voters re- Hoy- Representative construct a district Statewide, sixty-five sponded per “No.” er, member fourth ranked Democratic responded also “No.” When cent made Congress. Senator of the United States results, however, these aware of Senator “prevailing a reported that there was Pica replied, “[K]nowing Congressman Pica Assembly that the feeling” in the General Hoyer’s position Repre- in the House of Hoyer a “safe seat.” plan should assure sentatives, try I would still to reserve that congres- report was confirmed a This in the Congress.” status heard senators sional aid who several state Creating minority a district which discuss- floor of the senate chamber legisla- prompted not Hoyer would run were also ing to do so. The efforts efforts remaining seven dis- allocate the tors to the time. subject press much the repre- among eight incumbent tricts represent- expressed an Hoyer interest The of the dis- placement final sentatives. George’s he re- County, Prince where of the State in the center trict boundaries sides, Maryland, where as southern as well to eliminate the decision was determined he maintains a vacation home. former district Representative McMillan’s Hoyer Representative him, Hoyer, Bentley, The need to draw pit against perceived Cardin, Republican against junior arose from the “new” district but Gilchrist, of Wayne district in Dis- black-majority Representative, create a need to Indeed, precinct 1. George’s County along the north- trict Prince only one resides is the McMillan of the District of Columbia. border eastern included area which was Crofton George’s district in Prince Hoyer’s old County that Anne Arundel was portion of require- County would well have suited District swept bay across into “guar- ment, legislators wanted minority candidate the election antee” evidence, find that light of this if forced Hoyer lose and feared that to estab- not use neutral criteria State did minority As the State in a district. run eight districts. In- congressional lish explained, place- stead, driving force behind creating a plan], ment of the new district boundaries alternative while [An bids of cer- district, promote the election puts incumbent desire to minority a white representatives tain incumbent ex- I therefore Maryland’s conclude that pense other, less senior incumbents. redistricting plan as gives Constitution voters of contained in H.B. 10 violates the mandate Maryland right to make their own choices of Article plans such reelecting present about their Congress- equal representation direct and peo- represent men again them in Congress. and, ple, accordingly, I permit would not attempts State’s right defeat that proceed election to on the basis of H.B. 10. manipulating lines, district either unnec- essarily pitting against incumbents an- one reasons, the foregoing For I respectfully byor enhancing other prospects one dissent. another, candidate over cannot be recon- ciled with Wesberry.

APPENDIX

Case Details

Case Name: Anne Arundel County Republican Central Committee v. State Administrative Board of Election Laws

Court Name: District Court, D. Maryland

Date Published: Dec 23, 1991

Citation: 781 F. Supp. 394

Docket Number: Civ. A. S 91-3200

Court Abbreviation: D. Maryland