Supreme Court Decides Shapiro v. McManus
On December 8, 2015, the Supreme Court of the United States decided Shapiro v. McManus, No. 14-990, holding that a three-judge district court must be convened to decide a First Amendment challenge to Maryland's 2011 redrawing of its congressional districts.
By statute, a "district court of three judges shall be convened . . . when an action is filed challenging the constitutionality of the apportionment of congressional districts." 28 U.S.C. § 2284(a). The law further provides that "the judge [presented with a request for a three-judge court] shall, unless he determines that three judges are not required, immediately notify the chief judge of the circuit, who shall designate two other judges" to serve. Id. § 2284(b)(1). At issue was the meaning of the italicized "unless" clause.
Petitioners, a bipartisan group of Maryland residents, brought such a challenge, arguing that Maryland's 2011 redrawing of districts for the State's eight congressional seats violated their First Amendment right of political association. Petitioners also requested that a three-judge court decide their case. Instead of notifying the Chief Judge of the Fourth Circuit of the need for a three-judge court, the district court dismissed the case for the failure to state a claim. The Fourth Circuit affirmed.
The Supreme Court reversed and reinstated the lawsuit, ruling that section 2284 compelled the district court to provide notice to the Chief Judge that a three-judge panel needed to be convened. Focusing on section 2284's plain language, the Court concluded that the statute requires, absent a failure to raise a substantial federal question, that a district court refer a case "challenging the constitutionality of the apportionment of congressional districts" to a three-judge court. The Court read the statute's "unless" clause not as a "grant of discretion to the district judge to ignore" section 2284, but as an "administrative detail that is entirely compatible" with merely determining whether the case falls under section 2284. There is a difference, the Court said, "between failing to raise a substantial federal question for jurisdictional purposes . . . and failing to state a claim for relief on the merits . . . ." Only "wholly insubstantial and frivolous" claims implicate the Court's jurisdiction. "Absent such frivolity, ‘the failure to state a proper cause of action calls for a judgment on the merits, and not for a dismissal for want of jurisdiction.'" The Court determined the petitioners' claim "easily" cleared this low bar, requiring referral of their case to a three-judge panel.
Justice Scalia delivered the opinion for a unanimous Court.
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