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Virginia House of Delegates v. Bethune-Hill

Supreme Court of the United States
139 S. Ct. 1945, 204 L. Ed. 2d 305, 2019 U.S. LEXIS 4174 (2019)
ELI5:

Rule of Law:

A single chamber of a state's bicameral legislature lacks standing to appeal a federal court's judgment holding a state law unconstitutional when the state itself, through its authorized legal representative, has chosen not to appeal. The legislative chamber suffers no distinct, legally cognizable injury to its institutional powers and is not authorized to represent the State's interests in litigation unless state law so provides.


Facts:

  • In 2011, following the 2010 census, the Virginia General Assembly, which includes the House of Delegates, enacted a new legislative redistricting plan.
  • The plan established new electoral district boundaries for the state's House of Delegates.
  • A group of voters residing in 12 of the newly drawn House districts believed the districts were impermissibly designed based on race.
  • These voters alleged that the redistricting plan unconstitutionally sorted citizens into districts based on their skin color, in violation of the Equal Protection Clause.

Procedural Posture:

  • Voters sued Virginia state agencies and election officials (State Defendants) in the U.S. District Court for the Eastern District of Virginia, alleging racial gerrymandering.
  • The Virginia House of Delegates and its Speaker (the House) intervened in the lawsuit as defendants to defend the redistricting plan.
  • A three-judge District Court panel, after a bench trial, held that 11 of the challenged districts were unconstitutional racial gerrymanders.
  • The District Court enjoined Virginia from holding elections in the invalidated districts until a new plan was adopted.
  • Virginia's Attorney General announced that the Commonwealth of Virginia would not appeal the District Court's decision.
  • The House, acting alone as an intervenor-defendant, filed a notice of appeal to the U.S. Supreme Court.
  • The State Defendants filed a motion to dismiss the House's appeal for lack of standing.

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Issue:

Does a single chamber of a state legislature, the Virginia House of Delegates, have Article III standing to appeal a federal district court's decision holding a state redistricting law unconstitutional, when the State, through its Attorney General, has chosen not to appeal?


Opinions:

Majority - Justice Ginsburg

No. The Virginia House of Delegates lacks standing to appeal the District Court's ruling. The House lacks standing to represent the State's interests because Virginia law exclusively grants the Attorney General the authority to conduct civil litigation on behalf of the Commonwealth, and the Attorney General chose not to appeal. The House also lacks standing in its own right because it has not suffered a legally cognizable injury. The invalidation of a law that a legislative chamber helped pass does not constitute a discrete institutional injury. While redrawing district lines may affect the chamber's future membership, the House as an institution has no cognizable interest in the identity of its members or the content of legislation its future members may enact.


Dissenting - Justice Alito

Yes. The Virginia House of Delegates has standing to appeal because it suffers a clear injury-in-fact. A court-ordered replacement of a legislatively enacted districting plan inflicts a concrete and particularized injury on the legislative body itself. The boundaries of legislative districts powerfully affect a legislature's composition and, consequently, its legislative work and output. To suggest that substituting one plan for another has no effect on the legislative body is astounding. This direct institutional impact is a sufficient injury to establish Article III standing.



Analysis:

This decision clarifies and narrows the scope of legislative standing, particularly for individual chambers of a bicameral legislature. The Court established that a legislative body's general interest in defending the constitutionality of a law it helped enact is not, by itself, a sufficient injury for Article III standing. The ruling reinforces the principle that states have the authority to designate a single voice, typically the Attorney General, to represent their interests in litigation. This precedent may curtail the ability of partisan legislative factions to prolong legal battles over controversial laws, such as those concerning redistricting or voting rights, after the state's executive branch has decided to cease litigation.

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