Arizona State Legislature v. Arizona Independent Redistricting Commission Et Al.

An independent commission adopted by the voters of a state to redistrict maps for congressional and state legislative districts is valid under the Elections Clause in the U.S. Constitution.

In 2000, Arizona adopted Proposition 106, which removed the redistricting authority from the Legislature and put it into an independent commission, the Arizona Independent Redistricting Commission (AIRC). After the 2010 census, the AIRC created new maps for congressional and state legislative districts. Petitioner sued, arguing the AIRC and their new map violated the Elections Clause, Article I, Section 4, Clause 1, of the U.S. Constitution. The district court held Petitioner had standing to sue but rejected their complaint on the merits. The Court granted certiorari to address whether Petitioner had standing and whether the use of a commission to draw a map for congressional districts is allowed.

The Court affirmed the district court’s ruling, stating that Petitioner had standing to sue and that the AIRC is a valid avenue to use for adopting congressional districts. First, the Court held there was standing because the AIRC could nullify a vote by Petitioner if they voted on a redistricting plan. The Court held that there is history showing states have undertaken various routes to redistrict congressional lines, and the Elections Clause allows Arizona to create the AIRC if that is the will of the people. The State has the autonomy to create a process that works specifically for its own state without the interference of the federal government.