Shapiro v. McManus
84 U.S.L.W. 4015, 577 U.S. 39, 136 S. Ct. 450 (2015)
Rule of Law:
Under 28 U.S.C. § 2284, a single district judge is required to refer a challenge regarding the constitutionality of congressional district apportionment to a three-judge court unless the claim is wholly insubstantial or frivolous; the judge may not dismiss the case for failure to state a claim on the merits.
Facts:
- Following the 2010 Census, the State of Maryland enacted a new statute in October 2011 to establish boundaries for the state's eight congressional districts.
- A bipartisan group of citizens, serving as petitioners, believed the new map constituted an unconstitutional gerrymander that produced 'crazy-quilt' results.
- These citizens contended that the redistricting plan burdened their First Amendment rights of political association.
- The group sought to legally challenge the constitutionality of the state's apportionment of these districts.
Procedural Posture:
- Petitioners filed a pro se complaint in the Federal District Court for the District of Maryland requesting a three-judge court.
- The District Judge dismissed the complaint for failure to state a claim rather than convening a three-judge court.
- Petitioners appealed the dismissal to the U.S. Court of Appeals for the Fourth Circuit.
- The Fourth Circuit affirmed the District Judge's dismissal.
- Petitioners filed a petition for a writ of certiorari with the U.S. Supreme Court.
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Issue:
Does 28 U.S.C. § 2284 permit a single district judge to dismiss a challenge to the constitutionality of a congressional district apportionment for failure to state a claim, rather than convening a three-judge court?
Opinions:
Majority - Justice Scalia
No, a single district judge lacks the authority to dismiss such a case on the merits and must refer it to a three-judge court unless the claim is clearly frivolous. The Court reasoned that 28 U.S.C. § 2284(a) uses the mandatory 'shall,' creating an obligation impervious to discretion. The 'unless' clause in subsection (b)(1) is merely administrative, ensuring the case actually falls under the category of apportionment challenges, not an invitation to judge the merits. Furthermore, subsection (b)(3) explicitly forbids a single judge from entering judgment on the merits, and a dismissal for failure to state a claim is legally a judgment on the merits. The standard for bypassing the three-judge court is the 'wholly insubstantial' standard from Goosby v. Osser, which is much lower than the 'failure to state a claim' standard. Since the petitioners based their argument on a theory proposed by Justice Kennedy in a previous Supreme Court case (Vieth), the claim could not be deemed frivolous or wholly insubstantial.
Analysis:
This decision clarifies the limited role of single district judges in specialized statutory contexts requiring three-judge panels. By enforcing the strict textual reading of 28 U.S.C. § 2284, the Court prevents single judges from preemptively blocking constitutional challenges to redistricting based on their own assessment of the pleading's strength. It ensures that such significant political cases receive the intended heightened scrutiny of a three-judge panel and preserve the right of direct appeal to the Supreme Court. The ruling effectively lowers the barrier for plaintiffs to have their redistricting claims heard by the full designated panel.
