Lance v. Coffman

549 U.S. 437 (2007)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

The Elections Clause of the United States Constitution provides that the 'Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations, except as to the Places of chusing Senators.' Art. I, § 4, cl. 1. When Colorado legislators were unable to redraw congressional districts after the 2000 census to accommodate an additional Representative, a state court did it for them. Colorado's attorney general filed an original action to enjoin Colorado's secretary of state from implementing this new plan, noting that Article V, § 44, of the Colorado Constitution limits redistricting to once per census. he Colorado General Assembly intervened in the action to defend its plan. The Colorado Supreme Court granted the injunction, holding that 'judicially-created districts are just as binding and permanent as districts created by the General Assembly,' and that the court-drawn plan must remain in effect until the next decennial census. The court held this result did not offend the Elections Clause of the United States Constitution. Ps filed this action in Federal District Court. They argued that Article V, § 44, of the Colorado Constitution, as interpreted by the Colorado Supreme Court, violates their rights under the Elections Clause. The court determined that it lacked jurisdiction to hear the suit under Rooker-Feldman doctrine, but the Supreme Court vacated and remanded for further proceedings. On remand, the District Court held that Ps had standing to bring their Elections Clause challenge but the suit was barred by issue preclusion because Ps 'stand in privity with the Secretary of State and the General Assembly,' who were on the losing side in the prior litigation. Ps appealed again.