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Redistricting in Ohio after the 2020 census
Redistricting is the process of enacting new district boundaries for elected offices, particularly for offices in the U.S. House of Representatives and state legislatures. This article chronicles the 2020 redistricting cycle in Ohio.
Ohio's 15 United States representatives and 132 state legislators are all elected from political divisions called districts. District lines are redrawn every 10 years following completion of the United States census. Federal law stipulates that districts must have nearly equal populations and must not discriminate on the basis of race or ethnicity.
Congressional districts
Map drafting in Ohio after the 2020 census is ongoing.
On March 2, 2022, the Ohio Redistricting Commission approved a redrawn congressional map in a 5-2 vote along party lines, meaning the map lasted for four years.[1] On March 18, the Ohio Supreme Court ruled that it did not have jurisdiction to overturn the map before the state's primary elections as part of the legal challenge that overturned the initial congressional map.[2] This map took effect for Ohio's 2022 congressional elections. The legislature has until the end of September 2025 to pass a new map with three-fifths support in both chambers or the Ohio Redistricting Commission will take over to adopt a plan by October 31, 2025.[3]
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Legislative districts
Litigation over state legislative redistricting in Ohio after the 2020 census has concluded.
Due to a 2022 Ohio Supreme Court ruling, the Ohio Redistricting Commission was required to draw new state legislative maps following the 2022 elections.[4]
On September 26, 2023, the Ohio Redistricting Commission voted 6-0 (with one member absent) to adopt new state legislative maps.[5][6] On October 5, the ACLU of Ohio filed a motion on behalf of the League of Women Voters of Ohio and other plaintiffs asking the Ohio Supreme Court to invalidate the new state legislative maps on the grounds that they violated the state constitution.[7]
On November 27, the Ohio Supreme Court upheld the maps and dismissed the following cases: League of Women Voters of Ohio et al. v. Ohio Redistricting Commission et al., Bennett et al. v. Ohio Redistricting Commission et al., and Ohio Organizing Collaborative et al. v. Ohio Redistricting Commission et al.[8]
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See the sections below for further information on the following topics:
- Summary: This section provides summary information about the drafting and enacting processes.
- Apportionment and release of census data: This section details the 2020 apportionment process, including data from the United States Census Bureau.
- Drafting process: This section details the drafting process for new congressional and state legislative district maps.
- Enactment: This section provides information about the enacted congressional and state legislative district maps.
- Court challenges: This section details court challenges to the enacted congressional and state legislative district maps.
- Background: This section summarizes federal and state-based requirements for redistricting at both the congressional and state legislative levels. A summary of the 2010 redistricting cycle in Ohio is also provided.
Summary
This section lists major events in the post-2020 census redistricting cycle in reverse chronological order. Major events include the release of apportionment data, the release of census population data, the introduction of formal map proposals, the enactment of new maps, and noteworthy court challenges. Click the dates below for additional information.
Enactment
Enacted congressional district maps
Map drafting in Ohio after the 2020 census is ongoing.
Governor Mike DeWine (R) signed a new congressional map into law on November 20, 2021.[17] The Ohio State Senate voted 24-7 to approve the map on November 16.[18] The Ohio House of Representatives voted 55-36 to approve the map on November 18.[19]
On January 14, 2022, the Ohio Supreme Court struck down the state's enacted congressional map and ordered the Ohio State Legislature to redraw it.[20] On February 9, 2022, legislative leaders said they would not draw a new map, meaning the Ohio Redistricting Commission assumed responsibility for drawing the map.[21]
On September 7, 2023, the Ohio Supreme Court dismissed a lawsuit challenging the state's congressional district boundaries after the petitioners who filed the original lawsuit requested that the court dismiss the case and leave the boundaries in place for the 2024 election.[22]The U.S. Supreme Court had vacated a 2022 state supreme court decision that had overturned the state's 2022 congressional district boundaries[23] Since the congressional district boundaries that the state's redistricting commission adopted in March 2022 and which were used in the 2022 elections did not have support from members of the minority party, they were in effect for only two U.S. House elections with the commission required to enact a new map after the 2024 elections.
On March 2, 2022, the Ohio Redistricting Commission approved a redrawn congressional map in a 5-2 vote along party lines, meaning the map lasted for four years.[24] On March 18, the Ohio Supreme Court ruled that it did not have jurisdiction to overturn the map before the state's primary elections as part of the legal challenge that overturned the initial congressional map.[25] This map took effect for Ohio's 2022 congressional elections.
Below are the congressional maps in effect before and after the 2020 redistricting cycle.
Ohio Congressional Districts
until January 2, 2023
Click a district to compare boundaries.
Ohio Congressional Districts
starting January 3, 2023
Click a district to compare boundaries.
Reactions to the initial enacted congressional map
After signing the map, Governor. Mike DeWine (R) released a statement saying: "When compared to the other proposals offered from House and Senate caucuses, both Republican and Democrat, the map in Senate Bill 258 makes the most progress to produce a fair, compact, and competitive map."[17] Rep. Richard Brown (D) criticized the map, saying: "In my view, this was done for purely partisan political advantage, which is classic gerrymandering. It is sad and unfortunate that we are here at this point today. The people of Ohio deserve so much more."[26]
2020 presidential results
The table below details the results of the 2020 presidential election in each district at the time of the 2022 election and its political predecessor district.[27] This data was compiled by Daily Kos Elections.[28]
| 2020 presidential results by Congressional district, Ohio | ||||
|---|---|---|---|---|
| District | 2022 district | Political predecessor district | ||
Joe Biden 
|
Donald Trump 
|
Joe Biden
|
Donald Trump
| |
| Ohio's 1st | 53.5% | 45.0% | 47.7% | 50.9% |
| Ohio's 2nd | 26.7% | 72.0% | 42.9% | 55.6% |
| Ohio's 3rd | 71.1% | 27.4% | 70.0% | 28.4% |
| Ohio's 4th | 31.4% | 67.1% | 31.2% | 67.1% |
| Ohio's 5th | 35.8% | 62.6% | 36.7% | 61.6% |
| Ohio's 6th | 35.0% | 63.7% | 26.5% | 72.2% |
| Ohio's 7th | 44.8% | 54.0% | 42.2% | 56.5% |
| Ohio's 8th | 38.3% | 60.3% | 32.5% | 66.0% |
| Ohio's 9th | 47.7% | 50.6% | 58.8% | 39.7% |
| Ohio's 10th | 47.4% | 50.9% | 47.0% | 51.4% |
| Ohio's 11th | 78.3% | 20.7% | 79.8% | 19.2% |
| Ohio's 12th | 33.8% | 64.7% | 46.3% | 52.2% |
| Ohio's 13th | 50.7% | 47.9% | 51.0% | 47.6% |
| Ohio's 14th | 41.9% | 56.8% | 44.9% | 53.9% |
| Ohio's 15th | 45.8% | 52.6% | 42.2% | 56.3% |
Enacted state legislative district maps
Litigation over state legislative redistricting in Ohio after the 2020 census has concluded.
State legislative maps enacted in 2023
Due to a 2022 Ohio Supreme Court ruling, the Ohio Redistricting Commission was required to draw new state legislative maps following the 2022 elections.[29]
On September 26, 2023, the Ohio Redistricting Commission voted 6-0 (with one member absent) to adopt new state legislative maps.[30][31] On October 5, the ACLU of Ohio filed a motion on behalf of the League of Women Voters of Ohio and other plaintiffs asking the Ohio Supreme Court to invalidate the new state legislative maps on the grounds that they violated the state constitution.[32]
On November 27, the Ohio Supreme Court upheld the maps and dismissed the following cases: League of Women Voters of Ohio et al. v. Ohio Redistricting Commission et al., Bennett et al. v. Ohio Redistricting Commission et al., and Ohio Organizing Collaborative et al. v. Ohio Redistricting Commission et al.[8] Chief Justice Sharon Kennedy wrote for the majority: "The bipartisan adoption of the September 2023 plan is a changed circumstance that makes it appropriate to relinquish our continuing jurisdiction over these cases.[33]
The majority was composed of the court's four Republicans.
Justice Jennifer L. Brunner wrote a dissent on behalf of the court's other two Democrats, saying, "It is illusory to suggest that a bipartisan vote to adopt the September 2023 plan constitutes a change in circumstances that somehow diminishes our review power or renders a unanimous redistricting plan constitutionally compliant. There is nothing in Article XI, Section 6 that suggests that bipartisan agreement on a plan renders it presumptively constitutional, and we have flatly rejected that idea."[34]
State Senate
Below is the state Senate map in effect before and after the 2020 redistricting cycle. The map on the right was in effect for Ohio’s 2024 state legislative elections.
Ohio State Senate Districts
before 2020 redistricting cycle
Click a district to compare boundaries.
Ohio State Senate Districts
after 2020 redistricting cycle
Click a district to compare boundaries.
State House of Representatives
Below is the state House map in effect before and after the 2020 redistricting cycle. The map on the right was in effect for Ohio’s 2024 state legislative elections.
Ohio State House Districts
before 2020 redistricting cycle
Click a district to compare boundaries.
Ohio State House Districts
after 2020 redistricting cycle
Click a district to compare boundaries.
State legislative maps enacted in 2021-2022
A federal court ruling on Ohio's legislative maps took effect on May 28, 2022, which ordered maps drawn by the Ohio Redistricting Commission in February be used for the 2022 elections and set a legislative primary date of August 2.[35] These maps took effect for Ohio's 2022 state legislative elections.
The Ohio Redistricting Commission approved new state legislative district maps by a 5-2 vote on September 16, 2021. The two Democratic members of the commission, state Rep. Emilia Sykes (D) and state Sen. Vernon Sykes (D), dissented.[36] Senate President Matt Huffman (R), a member of the commission, estimated that the new maps would create 62 Republican seats and 37 Democratic seats in the House, and 23 Republican seats and 10 Democratic seats in the Senate. Cleveland.com reported that Democrats on the commission agreed with Huffman's Senate estimates, but said the new House map would create 65 Republican seats and 34 Democratic seats.[36] Thus, under the terms of the state's 2015 constitutional amendment, since the legislative district boundaries were passed strictly along partisan lines, they would only allowed to be used for elections in 2022 and 2024, and the commission was required to enact a new map by 2026.[37]
However, on January 12, 2022, the Ohio Supreme Court ruled against the state's enacted legislative maps, ordering the Ohio Redistricting Commission to redraw them within 10 days.[38] The commission voted to approve a new set of maps in a 5-2 vote on January 22. Click here to view the House map, and click here to view the Senate map.
On February 7, the Ohio Supreme Court rejected the state's redrawn legislative maps and ordered the Ohio Redistricting Commission to submit new maps.[39][40] The commission did not meet the February 17 deadline.[41] On February 24, the Ohio Redistricting Commission voted 4-3 to approve new legislative maps. State Auditor Keith Faber (R) joined the two Democratic members of the commission in voting against the maps.[42]
On March 16, the Ohio Supreme Court rejected the redrawn legislative maps and ordered the Ohio Redistricting Commission to draw new maps by March 28.[43] On March 22, the commission agreed to appoint two independent consultants to assist in the map-making process.[44] State Sen. Vernon Sykes (D) nominated University of Florida political science professor Michael McDonald and state Rep. Bob Cupp (R) nominated National Demographics Corporation president Douglas Johnson.[45]
On March 28, the Ohio Redistricting Commission approved new state legislative district boundaries in a 4-3 vote. DeWine, La Rose, Huffman, and Cupp voted to approve the new boundaries, and Russo, Sykes, and Faber voted against.[46] The commission approved maps it had drawn, since the Senate map drawn by the independent consultants was not complete at the time of the vote.[47]
On April 14, the Ohio Supreme Court rejected the Ohio Redistricting Commission's legislative maps for the fourth time and ordered the commission to redraw the maps by May 6.[48] On April 20, in a 2-1 decision, a panel of the U.S. District Court for the Southern District of Ohio issued an order saying it would not intervene to decide a primary date or map until May 28. If the state court proceedings did not produce a map by May 28, the court said it would order the primary to take place on August 2 using the third set of maps adopted by the Ohio Redistricting Commission.[49] The state court proceedings did not produce a map by May 28, so the order took effect.[35]
On May 5, the commission voted 4-3 to resubmit legislative maps it had previously submitted to the court on February 24.[50] DeWine, La Rose, Huffman, and Cupp voted to approve the boundaries, and Russo, Sykes, and Faber voted against.[51] The Ohio Supreme Court struck down the maps on May 25 and ordered the commission to redraw them by June 3.[52]
On May 27, in a 2-1 decision, a federal panel ordered the maps to be implemented for the 2022 election.[53]
Reactions to 2021-2022 state legislative maps
A statement from the commission explaining the manner by which districts were allocated said: "The Commission considered statewide state and federal partisan general election results during the last ten years. There were sixteen such contests. When considering the results of each of those elections, the Commission determined that Republican candidates won thirteen out of sixteen of those elections. [...] Accordingly, the statewide proportion of districts whose voters favor each political party corresponds closely to the statewide preferences of the voters of Ohio."[54]
Following the enactment of the maps, Huffman released a statement saying: “These house and senate maps will be in place for the next four years, and represent an important first step towards approving the next map that will complete the decade. [...] I’m convinced we could’ve reached a ten-year map. However, special interests pressured democrats to not support it, asking voters to extend the deadline to accomplish that.”[55]
Leading up to the vote, Emilia Sykes disapproved of the maps saying they were overly partisan and she would “call it offensive and plain wrong to move forward this map [...] to put forth something that so arrogantly flies in the face of what people, our voters, asked us to do, not once, but twice.”[36]
Commission members Gov. Mike DeWine (R) and Secretary of State Frank LaRose (R) expressed disapproval of the maps and said they expected court challenges to follow their vote. DeWine said: “Along with the secretary of state I will vote to send this matter forward but it will not be the end of it. We know that this matter will be in court. [...] What I am sure in my heart is that this committee could have come up with a bill that was much more clearly constitutional.”[56]
Drafting process
In Ohio, the state legislature or a commission may have the opportunity to draw congressional maps. A bipartisan state legislative commission draws state legislative maps. A six-member advisory commission is involved in both the congressional and state legislative redistricting processes.
Timeline of 2021-2022 map adoption
On August 2, 2021, Governor Mike DeWine (R) announced the Ohio Redistricting Commission would hold its first meeting on August 6.[57] The commission did not meet the first legislative map completion deadline of September 1. The second and final deadline was September 15.
The first congressional map deadline was September 30. Senate President Matt Huffman (R) said he did not expect the legislature to meet the congressional map deadline, saying: "I think it’s going to be – under the circumstances – difficult to meet for a couple of reasons."[58] Since a congressional map wasn't completed by that date, the Ohio Redistricting Commission had to draw a map by October 31. Since the commission did not adopt a map, the General Assembly had to draw a map by November 30.[59]
Redistricting committees and/or commissions in 2021-2022
In Ohio, the Ohio Redistricting Commission and the Joint Committee on Redistricting are involved in the redistricting process. As of February 24, 2022, the commission and committee had the following members:[60][61][62] On May 3, 2022, state Sen. Matt Huffman resigned from the commission and was replaced by state Sen. Robert McColley (R).
| Ohio Joint Committee on Redistricting membership, 2020 cycle | |
|---|---|
| Name | Partisan affiliation |
| State Sen. Theresa Gavarone | Republican
|
| State Sen. Rob McColley | Republican
|
| State Sen. Vernon Sykes | Democratic
|
| State Rep. Beth Liston | Democratic
|
| State Rep. Scott Oelslager | Republican
|
| State Rep. Shane Wilkin | Republican
|
| Ohio Redistricting Commission membership, 2020 cycle | |
|---|---|
| Name | Partisan affiliation |
| State Rep. Bob Cupp Co-Chair | Republican
|
| State Sen. Vernon Sykes Co-Chair | Democratic
|
| Gov. Mike DeWine | Republican
|
| Secretary of State Frank LaRose | Republican
|
| State Auditor Keith Faber | Republican
|
| State Sen. Robert McColley | Republican
|
| State Rep. Allison Russo | Democratic
|
Drafts and proposals
Legislative maps
A draft map from the Ohio Senate Democratic Caucus was released during the Aug. 31 meeting of the Ohio Redistricting Commission.[63] In a Sept. 9 meeting of the commission, Republican members released map proposals that were adopted by the commission in a 5-2 vote along party lines.[64]
Images of the Aug. 31 Democratic map drafts are linked below.
- Click here to view a map of the Aug. 31 Senate Democratic Caucus proposal.
Images of the Sept. 9 Republican map proposals adopted by the commission are linked below.
- Click here to view an interactive version of the Sept. 9 Republican Ohio House of Representatives proposal.
- Click here to view an interactive version of the Sept. 9 Republican Ohio Senate proposal.
On February 11, 2022, after the Ohio Supreme Court struck down the enacted maps, Democratic members of the state legislature released legislative map proposals.[65] The state Senate map can be viewed here, and the state House map can be viewed here.
Reactions
Following the Sept. 9 release of the commission's official map proposals, Sen. Vernon Sykes (D) said the proposed maps provided Republicans with an advantage, saying: "I don’t blame the Speaker of the House or the Senate president for doing the best they can to craft districts to help their caucus. To present a map before this commission and say they aren't aware of what it is and didn't consider it at all, I think is disingenuous."[66] Sen. Matt Huffman (R) said that partisan advantage had not been taken into consideration while drawing the maps, saying: "The definition of gerrymandering is designing districts to benefit a particular political party so if we simply say we must design this so that 55%, 55 seats in the Ohio House of Representatives are Republican, that's gerrymandering."[66]
In a Sept. 13 meeting, Democratic commission members introduced a revised version of the Sept. 9 Republican proposal. The maps for the House and Senate were proposed before the commission, but they were not formally adopted. In a joint statement, Sen. Sykes and Rep. Emilia Sykes (D) said: "We hope the Republican members of the Commission were serious when they said they want to work with us to improve these maps and put us on a path to passing a bipartisan, 10-year plan."[67]
Congressional maps
On Sept. 30, state Sens. Kenny Yuko (D) and Vernon Sykes (D) proposed a congressional redistricting map.[68] On Nov. 10, Yuko and Sykes submitted an amended version of the proposal.[69] On November 3, Republican lawmakers released two additional map proposals.[70] On November 5, Democratic lawmakers in the state house released a congressional map proposal.[71]
On Nov. 15, Republican lawmakers in the state House and Senate released a joint map proposal.[72]
Apportionment and release of census data
Apportionment is the process by which representation in a legislative body is distributed among its constituents. The number of seats in the United States House of Representatives is fixed at 435. The United States Constitution dictates that districts be redrawn every 10 years to ensure equal populations between districts. Every ten years, upon completion of the United States census, reapportionment occurs.[73]
Apportionment following the 2020 census
The U.S. Census Bureau delivered apportionment counts on April 26, 2021. Ohio was apportioned 15 seats in the U.S. House of Representatives. This represented a net loss of one seat as compared to apportionment after the 2010 census.[74]
See the table below for additional details.
| 2020 and 2010 census information for Ohio | |||||||
|---|---|---|---|---|---|---|---|
| State | 2010 census | 2020 census | 2010-2020 | ||||
| Population | U.S. House seats | Population | U.S. House seats | Raw change in population | Percentage change in population | Change in U.S. House seats | |
| Ohio | 11,568,495 | 16 | 11,808,848 | 15 | 240,353 | 2.08% | -1 |
Redistricting data from the Census Bureau
On February 12, 2021, the Census Bureau announced that it would deliver redistricting data to the states by September 30, 2021. On March 15, 2021, the Census Bureau released a statement indicating it would make redistricting data available to the states in a legacy format in mid-to-late August 2021. A legacy format presents the data in raw form, without data tables and other access tools. On May 25, 2021, Ohio Attorney General Dave Yost (R) announced that the state had reached a settlement agreement with the Census Bureau in its lawsuit over the Census Bureau's timetable for delivering redistricting data. Under the terms of the settlement, the Census Bureau agreed to deliver redistricting data, in a legacy format, by August 16, 2021.[75][76][77][78] The Census Bureau released the 2020 redistricting data in a legacy format on August 12, 2021, and in an easier-to-use format at data.census.gov on September 16, 2021.[79][80]
Court challenges
- If you are aware of any relevant lawsuits that are not listed here, please email us at editor@ballotpedia.org.
Post-enactment lawsuits
This section provides overviews of lawsuits challenging redistricting maps that were filed after Ohio enacted maps for the 2020 redistricting cycle.
Neiman v. LaRose
- Note: This case was also known as Huffman v. Neiman when Ohio State Senate President Matt Huffman appealed the Ohio Supreme Court's decision to the U.S. Supreme Court.
On March 21, the National Redistricting Action Fund filed a lawsuit before the Ohio Supreme Court on behalf of several Ohio residents, including two who were previously involved in other congressional redistricting lawsuits during the 2020 redistricting cycle, challenging the congressional map approved by the Ohio Redistricting Commission on March 2.[81] In the suit, the plaintiffs said the map "bears a striking resemblance to the plan struck down by the Court on January 14, and is again infused with partisan bias. It is an extreme partisan outlier again. It eschews sensible, compact districts that respect Ohio’s political geography precisely because doing so would not result in extreme partisan advantage at odds with Ohio’s voting patterns." The plaintiffs requested the court invalidate the March 2 congressional map, delay election-related deadlines and the congressional primary, and that the court choose a new map or order the General Assembly to adopt a new congressional map.[82] On March 29, 2022, the court set a schedule for this case in which it expected to review the congressional map after the May 3 primaries.[83]
On July 19, 2022, the Ohio Supreme Court ruled in a 4-3 decision that the congressional district boundaries that the Ohio Redistricting Commission adopted on March 2, 2022, were unconstitutional.[84] The 2022 congressional elections took place using the boundaries the redistricting commission adopted in March 2022 since primary elections were held using those districts on May 3, 2022.[84] Since the congressional district boundaries that the commission enacted did not have support from members of the minority party, the boundaries were in effect for only four years with the commission required to enact a new map after the 2024 elections. The state supreme court's order directed the Ohio General Assembly to pass a compliant plan within 30 days, and if the general assembly failed to do so, the court required that the redistricting commission adopt such a plan within an additional 30 days.[85]
Justices Maureen O'Connor, Michael P. Donnelly, and Melody Stewart signed the court's majority opinion and Justice Jennifer L. Brunner filed a concurring opinion. Justices Sharon L. Kennedy, Pat DeWine, and Pat Fischer wrote or joined dissenting opinions.[84]
In its decision, the court's opinion stated, "Petitioners have satisfied their burden by showing beyond a reasonable doubt that the March 2 plan unduly favors the Republican Party in violation of Article XIX, Section 1(C)(3)(a) of the Ohio Constitution. Comparative analyses and other metrics show that the March 2 plan allocates voters in ways that unnecessarily favor the Republican Party by packing Democratic voters into a few dense Democratic-leaning districts, thereby increasing the Republican vote share of the remaining districts. As a result, districts that would otherwise be strongly Democratic-leaning are now competitive or Republican-leaning districts."[85]
The dissenting opinion signed by Justices Kennedy and DeWine said, "We disagree, however, with the majority’s conclusion that the March 2 plan is invalid because it violates Article XIX, Section 1(C)(3)(a) of the Ohio constitution for “ ‘unduly favor[ing] or disfavor[ing] a political party or its incumbents.’...Therefore, we would hold that the March 2 plan is constitutional and order its use for the 2024 primary and general elections. Because the majority does otherwise, we dissent."[85]
On June 30, 2023, the Supreme Court of the United States vacated the Ohio Supreme Court decision and remanded the case for consideration in light of the Moore v. Harper decision.[86] The Ohio Supreme Court reopened the case on August 23, and the petitioners who filed the original lawsuit requested the court to dismiss the case and leave the boundaries in place for the 2024 election, citing the need for voter certainty heading into the 2024 election cycle. The court dismissed the case on September 7.[87]
Gonidakis v. Ohio Redistricting Commission
On February 18, 2022, a group of Ohio citizens filed a lawsuit in federal court asking the court to enact a set of legislative maps drawn by the Ohio Redistricting Commission. In the suit, the plaintiffs allege that the lack of enacted maps "has deprived Plaintiffs the opportunity to run for office, educate themselves about candidates, support candidates, and associate with like-minded voters, among other things" and that the "current state legislative districts (or lack thereof) violate the U.S. Constitution." The plaintiffs requested the court enact the second redistricting plan drawn by the Ohio Redistricting Commission, which had previously been struck down by the Ohio Supreme Court.[88]
On March 14, U.S. District Judge Algenon Marbley rejected the request to intervene pending future rulings from the Ohio Supreme Court on the state's legislative maps. He wrote that, "If that decision reveals serious doubts that state processes will produce a state map in time for the primary election, then the stay will be lifted and this case will proceed."[89] On March 18, Marbley lifted the stay on the case after the Ohio Supreme Court rejected the third set of legislative maps.[90]
On March 30, three judges on the United States Court of Appeals for the 6th Circuit ruled that at the time they would not select a map or primary election date.[91]
On April 20, the three-judge panel issued an order saying it would not intervene to decide a primary date or map until May 28. If the state court proceedings did not produce a map by May 28, the court said it would order the primary to take place on August 2 using the third set of maps adopted by the Ohio Redistricting Commission.[92] The state court proceedings did not produce a map by May 28, so the order took effect.[35]
Simon v. DeWine
On Nov. 30, 2021, two Ohio residents filed a federal lawsuit challenging the state's enacted congressional and state Senate maps in the United States District Court for the Northern District of Ohio. In the suit, the plaintiffs alleged the maps violated Section 2 of the Voting Rights Act and the 15th Amendment of the United States Constitution, saying: "the legislature leadership in Ohio intentionally disregarded whether the proposed districts diluted Black voting strength or the existence among other things, of racial block voting." The plaintiffs requested the court strike down the maps and order the maps to be redrawn.[93]
On January 12, 2022, U.S. District Judge John Adams paused proceedings in the case for 60 days, pending the results of state-level lawsuits against the legislative and congressional maps.[94] On January 12, the Ohio Supreme Court struck down the state's enacted legislative maps, and on January 14 the court also struck down the state's enacted congressional map.[20][95]
League of Women Voters of Ohio v. DeWine
On Nov. 30, 2021, League of Women Voters of Ohio and the A. Philip Randolph Institute filed a lawsuit on behalf of Ohio residents challenging the congressional map signed into law on Nov. 20.[96] In the suit, the plaintiffs said "Rather than reflecting voters’ actual preferences, Ohio’s newly enacted congressional map, like elections under gerrymandered systems, systematically locks in candidates from the Republican legislators’ preferred party and discourages electoral competition responsive to voters’ preferences." The lawsuit sought a determination that the enacted map was invalid.[97]
On Dec. 6, the court dismissed members of the Ohio Redistricting Commission from the lawsuit in their capacity as commissioners. The claims remained pending against Frank LaRose (R) in his capacity as secretary of state, Robert Cupp (R) in his capacity as speaker of the Ohio House of Representatives, and Matt Huffman in his capacity as Ohio State Senate president.[98]
In a 4-3 decision, the Ohio Supreme Court struck down the state's enacted congressional map and ordered the Ohio State Legislature to draw and approve a new map.[20] In the January 14, 2022, majority opinion Justice Michael P. Donnelly wrote: "When the dealer stacks the deck in advance, the house usually wins. That perhaps explains how a party that generally musters no more than 55 percent of the statewide popular vote is positioned to reliably win anywhere from 75 percent to 80 percent of the seats in the Ohio congressional delegation. By any rational measure, that skewed result just does not add up."[99]
Justices Sharon L. Kennedy, Pat Fischer, and Pat DeWine jointly dissented, writing: "The majority today declares the congressional-district plan enacted by the legislature to be unconstitutional on the basis that it “unduly” favors a political party and “unduly” splits governmental units. It does so without presenting any workable standard about what it means to unduly favor a political party or divide a county."[99]
The Ohio Redistricting Commission voted to approve a redrawn congressional map on March 2. On March 18, the Ohio Supreme Court ruled that it did not have jurisdiction to overturn the redrawn map in this case and Adams v. DeWine, allowing the redrawn congressional map to stand barring a ruling otherwise in a separate legal challenge.[100]
Adams v. DeWine
On Nov. 22, 2021, a group of Ohio residents represented by the National Redistricting Action Fund filed a lawsuit challenging the congressional map signed into law on Nov. 20.[101] In the suit, the plaintiffs said "the 2021 Congressional Plan unduly favors the Republican Party and its incumbents, while disfavoring the Democratic Party and its incumbents" and "excessively divides communities in northeast and southwest Ohio, despite that no other redistricting criterion (constitutional or otherwise) requires it to do so." The lawsuit sought a determination that the enacted map was invalid.[102]
On Dec. 3, the court dismissed members of the Ohio Redistricting Commission from the lawsuit in their capacity as commissioners, and dismissed Gov. Mike DeWine (R) in his capacity as governor as well. The claims remained pending against Frank LaRose (R) in his capacity as secretary of state, Robert Cupp (R) in his capacity as speaker of the Ohio House of Representatives, and Matt Huffman in his capacity as Ohio State Senate president.[103]
In a 4-3 decision, the Ohio Supreme Court struck down the state's enacted congressional map and ordered the Ohio State Legislature to draw and approve a new map.[20] In the January 14, 2022, majority opinion Justice Michael P. Donnelly wrote: "When the dealer stacks the deck in advance, the house usually wins. That perhaps explains how a party that generally musters no more than 55 percent of the statewide popular vote is positioned to reliably win anywhere from 75 percent to 80 percent of the seats in the Ohio congressional delegation. By any rational measure, that skewed result just does not add up."[99]
Justices Sharon L. Kennedy, Pat Fischer, and Pat DeWine jointly dissented, writing: "The majority today declares the congressional-district plan enacted by the legislature to be unconstitutional on the basis that it “unduly” favors a political party and “unduly” splits governmental units. It does so without presenting any workable standard about what it means to unduly favor a political party or divide a county."[99]
The Ohio Redistricting Commission voted to approve a redrawn congressional map on March 2. On March 18, the Ohio Supreme Court ruled that it did not have jurisdiction to overturn the redrawn map in this case and League of Women Voters of Ohio v. DeWine, allowing the redrawn congressional map to stand barring a ruling otherwise in a separate legal challenge.[100]
Ohio Organizing Collaborative, et al. v. Ohio Redistricting Commission, et al.
The Ohio Supreme Court dismissed this lawsuit when it ruled 4-3 on November 27, 2023, that the Ohio Redistricting Commission had approved its most recent maps in a bipartisan vote.[104]
On Sept. 27, 2021, the Ohio Organizing Collaborative (OOC) and several other organizations filed a lawsuit against the Ohio Redistricting Commission challenging the state legislative maps approved by the commission on Sept. 16. This was the third lawsuit filed against Ohio's state legislative maps.[105] In the suit, OOC said: "the district plan dilutes the voting power of Ohio voters who tend to support Democrats. [...] These abuses are especially borne by members of Ohio’s growing Black and Muslim communities who, because of Ohio’s political geography, are among the communities that bear the brunt of the enacted partisan gerrymander." The lawsuit sought a determination that the commission's enacted maps are invalid.[106]
In a 4-3 decision, the Ohio Supreme Court struck down the state's enacted legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[95] In the January 12, 2022, majority opinion Justice Melody J. Stewart wrote: "Although respondents have presented evidence showing that Ohio’s political geography and the map-drawing requirements of Article XI, Sections 3 and 4 may naturally lead to a district map’s favoring the Republican candidates, the evidence shows that these factors did not dictate as heavy a partisan skew as there is in the adopted plan. Petitioners have shown beyond a reasonable doubt that the commission did not attempt to draw a districting plan that meets the standard articulated in Section 6(A)." Article XI, Section 6(A) of the Ohio State Constitution requires that "[n]o general assembly district plan shall be drawn primarily to favor or disfavor a political party."[107]
Justice Sharon L. Kennedy dissented, writing: "The majority then rewrites the plain language of Section 9(B), which provides for the reconstitution of the commission after a plan has been found invalid, to make itself the object of the provision and grant this court sweeping authority to review any challenge to the General Assembly-district plan."[107]
On January 25, 2022, following the Ohio Redistricting Commission's release of a new map, the plaintiffs in this case filed a complaint against the new map before the Ohio Supreme Court.[108] They alleged the revised maps were unconstitutional in two ways: "First, the Commission enacted the new plan primarily to favor Republicans and disfavor Democrats, in violation of Section 6(A) of Article XI. [...] Second, the Commission’s Senate map does not meet the proportionality standard set out in Section 6(B) of Article XI."[109]
In a 4-3 decision, the Ohio Supreme Court struck down the second set of approved legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[39] The February 7 majority opinion said: "The revised plan does not attempt to closely correspond to that constitutionally defined ratio. Our instruction to the commission is—simply—to comply with the Constitution." Justices Sharon L. Kennedy and Pat DeWine wrote in a joint dissenting opinion: "It is apparent that in disregard of constitutional standards, four members of this court have now commandeered the redistricting process and that they will continue to reject any General Assembly-district plan until they get the plan they want."[110]
On February 17, the Ohio Redistricting Commission announced it would not meet the deadline to draw new maps.[41] On February 18, the Ohio Supreme Court ordered members of the commission to file responses detailing why they did not meet the deadline and why they should not be held in contempt of court.[111] Commissioners filed responses on February 23.[112]The court then ordered the commissioners to appear at a contempt hearing on March 1.[113] On February 25, the court postponed the hearings after the commission formally submitted maps to the court.[114]
On March 16, the Ohio Supreme Court struck down the Ohio Redistricting Commission's legislative maps for the third time. The majority opinion said, "We further order the commission to be reconstituted and to convene and that the commission draft and adopt an entirely new General Assembly–district plan that conforms with the Ohio Constitution." The deadline for the new maps was set for March 28. A dissenting opinion penned by Justices Kennedy and DeWine said, "The majority decrees electoral chaos. It issues an order all but guaranteed to disrupt an impending election and bring Ohio to the brink of a constitutional crisis."[43]
On March 28 the commission submitted new maps that it drew after voting to bypass maps drawn by independent consultants the commission had hired. On March 30, the court asked commission members to respond to claims that they should be held in contempt. The claims alleged that the maps submitted by the commission were too similar to the third set of maps that had been struck down.[47]
On April 14, the Ohio Supreme Court struck down the March 28 maps and ordered the Ohio Redistricting Commission to submit new maps by May 6.[48] On May 5, the Ohio Redistricting Commission voted 4-3 to submit legislative maps to the court that it had previously submitted on February 24.[51] The Ohio Supreme Court struck down the maps on May 25 and ordered the commission to redraw them by June 3.[115]
Bennett, et al. v. Ohio Redistricting Commission, et al.
The Ohio Supreme Court dismissed this lawsuit when it ruled 4-3 on November 27, 2023, that the Ohio Redistricting Commission had approved its most recent maps in a bipartisan vote.[116][117]
On Sept. 24, 2021, the National Redistricting Action Fund (NRAF) filed a lawsuit on behalf of several Ohio citizens against the Ohio Redistricting Commission challenging the state legislative maps approved by the commission on Sept. 16.[118] This was the second lawsuit filed against Ohio's state legislative maps. In the suit, the NRAF said the maps were unconstitutional because "the Commission flatly ignored constitutional deadlines for releasing its proposed maps" and "in blatant violation of its constitutional mandate, the Commission adopted maps without even considering a standard for proportional representation until after voting to approve the maps." The lawsuit sought "a determination that the 2021 Commission Plan is invalid."[119]
In a 4-3 decision, the Ohio Supreme Court struck down the state's enacted legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[95] In the January 12, 2022, majority opinion Justice Melody J. Stewart wrote: "Although respondents have presented evidence showing that Ohio’s political geography and the map-drawing requirements of Article XI, Sections 3 and 4 may naturally lead to a district map’s favoring the Republican candidates, the evidence shows that these factors did not dictate as heavy a partisan skew as there is in the adopted plan. Petitioners have shown beyond a reasonable doubt that the commission did not attempt to draw a districting plan that meets the standard articulated in Section 6(A)." Article XI, Section 6(A) of the Ohio State Constitution requires that "[n]o general assembly district plan shall be drawn primarily to favor or disfavor a political party."[107]
Justice Sharon L. Kennedy dissented, writing: "The majority then rewrites the plain language of Section 9(B), which provides for the reconstitution of the commission after a plan has been found invalid, to make itself the object of the provision and grant this court sweeping authority to review any challenge to the General Assembly-district plan."[107]
On January 25, 2022, following the Ohio Redistricting Commission's release of new legislative maps, the plaintiffs in this case filed a complaint against the new maps before the Ohio Supreme Court.[108] They alleged the revised maps violated Ohio Constitution in three ways: "First, the Remedial Plan violates the line-drawing requirements of Article XI, Section 3. [...] Second, the Remedial Plan violates Article XI, Section 6. [...] Third, the Commission violated both the letter and spirit of Article XI, Section 1."[120]
In a 4-3 decision, the Ohio Supreme Court struck down the second set of approved legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[39] The February 7 majority opinion said: "The revised plan does not attempt to closely correspond to that constitutionally defined ratio. Our instruction to the commission is—simply—to comply with the Constitution." Justices Sharon L. Kennedy and Pat DeWine wrote in a joint dissenting opinion: "It is apparent that in disregard of constitutional standards, four members of this court have now commandeered the redistricting process and that they will continue to reject any General Assembly-district plan until they get the plan they want."[110]
On February 17, the Ohio Redistricting Commission announced it would not meet the deadline to draw new maps.[41] On February 18, the Ohio Supreme Court ordered members of the commission to file responses detailing why they did not meet the deadline and why they should not be held in contempt of court.[111] Commissioners filed responses on February 23.[112]The court then ordered the commissioners to appear at a contempt hearing on March 1.[113] On February 25, the court postponed the hearings after the commission formally submitted maps to the court.[114]
On March 16, the Ohio Supreme Court struck down the Ohio Redistricting Commission's legislative maps for the third time. The majority opinion said, "We further order the commission to be reconstituted and to convene and that the commission draft and adopt an entirely new General Assembly–district plan that conforms with the Ohio Constitution." The deadline for the new maps was set for March 28. A dissenting opinion penned by Justices Kennedy and DeWine said, "The majority decrees electoral chaos. It issues an order all but guaranteed to disrupt an impending election and bring Ohio to the brink of a constitutional crisis."[43]
On March 28 the commission submitted new maps that it drew after voting to bypass maps drawn by independent consultants the commission had hired. On March 30, the court asked commission members to respond to claims that they should be held in contempt. The claims alleged that the maps submitted by the commission were too similar to the third set of maps that had been struck down.[47]
On April 14, the Ohio Supreme Court struck down the March 28 maps and ordered the Ohio Redistricting Commission to submit new maps by May 6.[48] On May 5, the Ohio Redistricting Commission voted 4-3 to submit legislative maps to the court that it had previously submitted on February 24.[51] The Ohio Supreme Court struck down the maps on May 25 and ordered the commission to redraw them by June 3.[115]
League of Women Voters of Ohio, et. al. v. Ohio Redistricting Commission, et al.
The Ohio Supreme Court dismissed this lawsuit and upheld the state's legislative maps on November 27, 2023.[117]
On Sept. 23, 2021, the American Civil Liberties Union (ACLU) of Ohio, on behalf of the League of Women Voters of Ohio, filed a lawsuit with the Ohio Supreme Court against the Ohio Redistricting Commission challenging the state legislative maps approved by the commission on Sept. 16.[121] This was the first lawsuit filed against the Ohio maps specifically, and the first lawsuit filed against redistricting maps after the 2020 census.[122] In the lawsuit, the Ohio ACLU said the map "fails to correspond with voters’ preferences as manifested by the vote share of the two major parties’ candidates over the past decade" and "def[ies] a constitutional amendment adopted overwhelmingly by Ohio voters just six years ago, which sought to put an end to precisely this kind of extreme partisan gerrymandering." The lawsuit sought "a determination that the apportionment plan adopted by the Ohio Redistricting Commission is invalid."[123]
In a 4-3 decision, the Ohio Supreme Court struck down the state's enacted legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[95] In the January 12, 2022, majority opinion Justice Melody J. Stewart wrote: "Although respondents have presented evidence showing that Ohio’s political geography and the map-drawing requirements of Article XI, Sections 3 and 4 may naturally lead to a district map’s favoring the Republican candidates, the evidence shows that these factors did not dictate as heavy a partisan skew as there is in the adopted plan. Petitioners have shown beyond a reasonable doubt that the commission did not attempt to draw a districting plan that meets the standard articulated in Section 6(A)." Article XI, Section 6(A) of the Ohio State Constitution requires that "[n]o general assembly district plan shall be drawn primarily to favor or disfavor a political party."[107]
Justice Sharon L. Kennedy dissented, writing: "The majority then rewrites the plain language of Section 9(B), which provides for the reconstitution of the commission after a plan has been found invalid, to make itself the object of the provision and grant this court sweeping authority to review any challenge to the General Assembly-district plan."[107]
On January 25, 2022, following the Ohio Redistricting Commission's release of new legislative maps, the plaintiffs in this case filed a complaint against the new maps before the Ohio Supreme Court.[108] They alleged the revised maps violated Article XI of the Ohio Constitution in three ways: "First, the Revised Senate Map violates Section 6(B) because in drawing the map, the Commission deviated further from proportionality than required by any other provision of Article XI. Second, the Revised House Map also violates Section 6(B) because it also deviates further from proportionality than required by any other provision of Article XI. Third, the Commission drew its Revised House Map to primarily favor the Republican Party, in violation of Section 6(A)."[124]
In a 4-3 decision, the Ohio Supreme Court struck down the second set of approved legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days, at which point the court would review the maps and allow three days for objections to be filed.[39] The February 7 majority opinion said: "The revised plan does not attempt to closely correspond to that constitutionally defined ratio. Our instruction to the commission is—simply—to comply with the Constitution." Justices Sharon L. Kennedy and Pat DeWine wrote in a joint dissenting opinion: "It is apparent that in disregard of constitutional standards, four members of this court have now commandeered the redistricting process and that they will continue to reject any General Assembly-district plan until they get the plan they want."[110]
On February 17, the Ohio Redistricting Commission announced it would not meet the deadline to draw new maps.[41] On February 18, the Ohio Supreme Court ordered members of the commission to file responses detailing why they did not meet the deadline and why they should not be held in contempt of court.[111] Commissioners filed responses on February 23.[112] The court then ordered the commissioners to appear at a contempt hearing on March 1.[113] On February 25, the court postponed the hearings after the commission formally submitted maps to the court.[114]
On March 16, the Ohio Supreme Court struck down the Ohio Redistricting Commission's legislative maps for the third time. The majority opinion said, "We further order the commission to be reconstituted and to convene and that the commission draft and adopt an entirely new General Assembly–district plan that conforms with the Ohio Constitution." The deadline for the new maps was set for March 28. A dissenting opinion penned by Justices Kennedy and DeWine said, "The majority decrees electoral chaos. It issues an order all but guaranteed to disrupt an impending election and bring Ohio to the brink of a constitutional crisis."[43]
On March 28, the commission submitted new maps that it drew after voting to bypass maps drawn by independent consultants the commission had hired. On March 30, the court asked commission members to respond to claims that they should be held in contempt. The claims alleged that the maps submitted by the commission were too similar to the third set of maps that had been struck down.[47]
On April 14, the Ohio Supreme Court struck down the March 28 maps and ordered the Ohio Redistricting Commission to submit new maps by May 6.[48] On May 5, the Ohio Redistricting Commission voted 4-3 to submit legislative maps to the court that it had previously submitted on February 24.[51] The Ohio Supreme Court struck down the maps on May 25 and ordered the commission to redraw them by June 3.[115]
Pre-enactment lawsuits
This section provides overviews of lawsuits related to redistricting that were filed before Ohio enacted congressional or legislative maps for the 2020 redistricting cycle.
Ohio v. Raimondo
On February 25, 2021, the state of Ohio filed suit against Census Bureau officials in the U.S. District Court for the Southern District of Ohio. In his complaint, Ohio Solicitor General Benjamin Flowers said, "The unavailability of decennial census data irreparably harms the State: the Ohio Constitution requires the State to use decennial census data during redistricting if the data is available, and allows the use of alternative data sources only as a second-best option. By blocking the State from conducting redistricting using decennial census data, the Census Bureau's decision prevents the State from conducting redistricting in the constitutionally preferred manner." The state asked that the court "issue an injunction either prohibiting the defendants from delaying the release of Ohio's redistricting data beyond March 31, 2021, or else requiring the defendants to provide the State with Ohio's population data at the earliest date this Court deems equitable." The case was assigned to Judge Thomas Rose, a George W. Bush (R) appointee. Rose dismissed the lawsuit on March 24, 2021, writing, "The Court will therefore reject Ohio's request for an order that pretends that the Census Bureau could provide census-based redistricting data by March 31, 2021. The Court cannot 'order a party to jump higher, run faster, or lift more than she is physically capable.'"[125][126]
On March 25, 2021, the state appealed Rose's decision to the U.S. Court of Appeals for the Sixth Circuit. Oral argument before the Sixth Circuit was scheduled for May 12, 2021. On May 18, 2021, a three-judge panel of the Sixth Circuit ruled that Ohio met all three requirements for standing to bring a lawsuit: "First, Ohio suffered (and continues to suffer) an informational injury because the Secretary failed to deliver Ohio's data as the Census Act requires. Second, the injury is traceable to the Secretary because Ohio's informational injury is the direct result of the Secretary's failure to produce the required data. And third, Ohio's injury is redressable." The panel unanimously remanded the case to the district court for further consideration. The three judges on the panel were Martha Daughtrey (a Bill Clinton (D) appointee), David McKeague (a George W. Bush (R) appointee), and Amul Thapar (a Donald Trump (R) appointee).[127][128][129]
On May 25, 2021, Ohio Attorney General Dave Yost (R) announced that the state had reached a settlement agreement with the Census Bureau. Under the terms of the settlement, the Census Bureau agreed to deliver redistricting data, in a legacy format, by August 16, 2021. A legacy format presents the data in raw form, without data tables and other access tools. The Census Bureau also agreed to deliver biweekly updates (and, in August, weekly updates) on its progress. Yost said, "This administration tried to drag its feet and bog this down in court, but Ohio always had the law on its side and now the federal government has finally agreed. It’s time to cough up the data." As of May 26, 2021, the Census Bureau had not commented publicly on the settlement.[77]
The Census Bureau had previously indicated that redistricting data would be made available to states in a legacy format by mid-to-late August 2021, saying the following in a statement released on March 15, 2021: “In declarations recently filed in the case of Ohio v. Raimondo, the U.S. Census Bureau made clear that we can provide a legacy format summary redistricting data file to all states by mid-to-late August 2021. Because we recognize that most states lack the capacity or resources to tabulate the data from these summary files on their own, we reaffirm our commitment to providing all states tabulated data in our user-friendly system by Sept. 30, 2021.”[78]
Background
This section includes background information on federal requirements for congressional redistricting, state legislative redistricting, state-based requirements, redistricting methods used in the 50 states, gerrymandering, and recent court decisions.
Federal requirements for congressional redistricting
According to Article I, Section 4 of the United States Constitution, the states and their legislatures have primary authority in determining the "times, places, and manner" of congressional elections. Congress may also pass laws regulating congressional elections.[130][131]
| “ | The Times, Places and 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.[132] | ” |
| —United States Constitution | ||
Article I, Section 2 of the United States Constitution stipulates that congressional representatives be apportioned to the states on the basis of population. There are 435 seats in the United States House of Representatives. Each state is allotted a portion of these seats based on the size of its population relative to the other states. Consequently, a state may gain seats in the House if its population grows or lose seats if its population decreases, relative to populations in other states. In 1964, the United States Supreme Court ruled in Wesberry v. Sanders that the populations of House districts must be equal "as nearly as practicable."[133][134][135]
The equal population requirement for congressional districts is strict. According to All About Redistricting, "Any district with more or fewer people than the average (also known as the 'ideal' population), must be specifically justified by a consistent state policy. And even consistent policies that cause a 1 percent spread from largest to smallest district will likely be unconstitutional."[135]
Federal requirements for state legislative redistricting
The United States Constitution is silent on the issue of state legislative redistricting. In the mid-1960s, the United States Supreme Court issued a series of rulings in an effort to clarify standards for state legislative redistricting. In Reynolds v. Sims, the court ruled that "the Equal Protection Clause [of the United States Constitution] demands no less than substantially equal state legislative representation for all citizens, of all places as well as of all races." According to All About Redistricting, "it has become accepted that a [redistricting] plan will be constitutionally suspect if the largest and smallest districts [within a state or jurisdiction] are more than 10 percent apart."[135]
State-based requirements
In addition to the federal criteria noted above, individual states may impose additional requirements on redistricting. Common state-level redistricting criteria are listed below.
- Contiguity refers to the principle that all areas within a district should be physically adjacent. A total of 49 states require that districts of at least one state legislative chamber be contiguous (Nevada has no such requirement, imposing no requirements on redistricting beyond those enforced at the federal level). A total of 23 states require that congressional districts meet contiguity requirements.[135][136]
- Compactness refers to the general principle that the constituents within a district should live as near to one another as practicable. A total of 37 states impose compactness requirements on state legislative districts; 18 states impose similar requirements for congressional districts.[135][136]
- A community of interest is defined by FairVote as a "group of people in a geographical area, such as a specific region or neighborhood, who have common political, social or economic interests." A total of 24 states require that the maintenance of communities of interest be considered in the drawing of state legislative districts. A total of 13 states impose similar requirements for congressional districts.[135][136]
- A total of 42 states require that state legislative district lines be drawn to account for political boundaries (e.g., the limits of counties, cities, and towns). A total of 19 states require that similar considerations be made in the drawing of congressional districts.[135][136]
Methods
In general, a state's redistricting authority can be classified as one of the following:[137]
- Legislature-dominant: In a legislature-dominant state, the legislature retains the ultimate authority to draft and enact district maps. Maps enacted by the legislature may or may not be subject to gubernatorial veto. Advisory commissions may also be involved in the redistricting process, although the legislature is not bound to adopt an advisory commission's recommendations.
- Commission: In a commission state, an extra-legislative commission retains the ultimate authority to draft and enact district maps. A non-politician commission is one whose members cannot hold elective office. A politician commission is one whose members can hold elective office.
- Hybrid: In a hybrid state, the legislature shares redistricting authority with a commission.
Gerrymandering
- See also: Gerrymandering
The term gerrymandering refers to the practice of drawing electoral district lines to favor one political party, individual, or constituency over another. When used in a rhetorical manner by opponents of a particular district map, the term has a negative connotation but does not necessarily address the legality of a challenged map. The term can also be used in legal documents; in this context, the term describes redistricting practices that violate federal or state laws.[138][139]
For additional background information about gerrymandering, click "[Show more]" below.
The phrase racial gerrymandering refers to the practice of drawing electoral district lines to dilute the voting power of racial minority groups. Federal law prohibits racial gerrymandering and establishes that, to combat this practice and to ensure compliance with the Voting Rights Act, states and jurisdictions can create majority-minority electoral districts. A majority-minority district is one in which a racial group or groups comprise a majority of the district's populations. Racial gerrymandering and majority-minority districts are discussed in greater detail in this article.[140]
The phrase partisan gerrymandering refers to the practice of drawing electoral district maps with the intention of favoring one political party over another. In contrast with racial gerrymandering, on which the Supreme Court of the United States has issued rulings in the past affirming that such practices violate federal law, the high court had not, as of November 2017, issued a ruling establishing clear precedent on the question of partisan gerrymandering. Although the court has granted in past cases that partisan gerrymandering can violate the United States Constitution, it has never adopted a standard for identifying or measuring partisan gerrymanders. Partisan gerrymandering is described in greater detail in this article.[141][142]Recent court decisions
The Supreme Court of the United States has, in recent years, issued several decisions dealing with redistricting policy, including rulings relating to the consideration of race in drawing district maps, the use of total population tallies in apportionment, and the constitutionality of redistricting commissions. The rulings in these cases, which originated in a variety of states, impact redistricting processes across the nation.
For additional background information about these cases, click "[Show more]" below.
Alexander v. South Carolina State Conference of the NAACP (2024)
Alexander v. South Carolina State Conference of the NAACP — This case concerns a challenge to the congressional redistricting plan that the South Carolina legislature enacted after the 2020 census. In January 2023, a federal three-judge panel ruled that the state's 1st Congressional District was unconstitutional and enjoined the state from conducting future elections using its district boundaries. The panel's opinion said, "The Court finds that race was the predominant factor motivating the General Assembly’s adoption of Congressional District No. 1...Defendants have made no showing that they had a compelling state interest in the use of race in the design of Congressional District No. 1 and thus cannot survive a strict scrutiny review."[143] Thomas Alexander (R)—in his capacity as South Carolina State Senate president—appealed the federal court's ruling, arguing: :In striking down an isolated portion of South Carolina Congressional District 1 as a racial gerrymander, the panel never even mentioned the presumption of the General Assembly’s “good faith.”...The result is a thinly reasoned order that presumes bad faith, erroneously equates the purported racial effect of a single line in Charleston County with racial predominance across District 1, and is riddled with “legal mistake[s]” that improperly relieved Plaintiffs of their “demanding” burden to prove that race was the “predominant consideration” in District 1.[144] The U.S. Supreme Court scheduled oral argument on this case for October 11, 2023.[145]
Moore v. Harper (2023)
- See also: Moore v. Harper
At issue in Moore v. Harper, was whether state legislatures alone are empowered by the Constitution to regulate federal elections without oversight from state courts, which is known as the independent state legislature doctrine. On November 4, 2021, the North Carolina General Assembly adopted a new congressional voting map based on 2020 Census data. The legislature, at that time, was controlled by the Republican Party. In the case Harper v. Hall (2022), a group of Democratic Party-affiliated voters and nonprofit organizations challenged the map in state court, alleging that the new map was a partisan gerrymander that violated the state constitution.[146] On February 14, 2022, the North Carolina Supreme Court ruled that the state could not use the map in the 2022 elections and remanded the case to the trial court for further proceedings. The trial court adopted a new congressional map drawn by three court-appointed experts. The United States Supreme Court affirmed the North Carolina Supreme Court's original decision in Moore v. Harper that the state's congressional district map violated state law. In a 6-3 decision, Chief Justice John Roberts wrote that the "Elections Clause does not vest exclusive and independent authority in state legislatures to set the rules regarding federal elections.[147]
Merrill v. Milligan (2023)
- See also: Merrill v. Milligan
At issue in Merrill v. Milligan, was the constitutionality of Alabama's 2021 redistricting plan and whether it violated Section 2 of the Voting Rights Act. A group of Alabama voters and organizations sued Secretary of State John Merrill (R) and the House and Senate redistricting chairmen, Rep. Chris Pringle (R) and Sen. Jim McClendon (R). Plaintiffs alleged the congressional map enacted on Nov. 4, 2021, by Gov. Kay Ivey (R) unfairly distributed Black voters. The plaintiffs asked the lower court to invalidate the enacted congressional map and order a new map with instructions to include a second majority-Black district. The court ruled 5-4, affirming the lower court opinion that the plaintiffs showed a reasonable likelihood of success concerning their claim that Alabama's redistricting map violated Section 2 of the Voting Rights Act.[148]
Gill v. Whitford (2018)
- See also: Gill v. Whitford
In Gill v. Whitford, decided on June 18, 2018, the Supreme Court of the United States ruled that the plaintiffs—12 Wisconsin Democrats who alleged that Wisconsin's state legislative district plan had been subject to an unconstitutional gerrymander in violation of the First and Fourteenth Amendments—had failed to demonstrate standing under Article III of the United States Constitution to bring a complaint. The court's opinion, penned by Chief Justice John Roberts, did not address the broader question of whether partisan gerrymandering claims are justiciable and remanded the case to the district court for further proceedings. Roberts was joined in the majority opinion by Associate Justices Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito, Sonia Sotomayor, and Elena Kagan. Kagan penned a concurring opinion joined by Ginsburg, Breyer, and Sotomayor. Associate Justice Clarence Thomas penned an opinion that concurred in part with the majority opinion and in the judgment, joined by Associate Justice Neil Gorsuch.[149]
Cooper v. Harris (2017)
- See also: Cooper v. Harris
In Cooper v. Harris, decided on May 22, 2017, the Supreme Court of the United States affirmed the judgment of the United States District Court for the Middle District of North Carolina, finding that two of North Carolina's congressional districts, the boundaries of which had been set following the 2010 United States Census, had been subject to an illegal racial gerrymander in violation of Section 2 of the Voting Rights Act. Justice Elena Kagan delivered the court's majority opinion, which was joined by Justices Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, and Sonia Sotomayor (Thomas also filed a separate concurring opinion). In the court's majority opinion, Kagan described the two-part analysis utilized by the high court when plaintiffs allege racial gerrymandering as follows: "First, the plaintiff must prove that 'race was the predominant factor motivating the legislature's decision to place a significant number of voters within or without a particular district.' ... Second, if racial considerations predominated over others, the design of the district must withstand strict scrutiny. The burden shifts to the State to prove that its race-based sorting of voters serves a 'compelling interest' and is 'narrowly tailored' to that end." In regard to the first part of the aforementioned analysis, Kagan went on to note that "a plaintiff succeeds at this stage even if the evidence reveals that a legislature elevated race to the predominant criterion in order to advance other goals, including political ones." Justice Samuel Alito delivered an opinion that concurred in part and dissented in part with the majority opinion. This opinion was joined by Chief Justice John Roberts and Justice Anthony Kennedy.[150][151][152]
Evenwel v. Abbott (2016)
- See also: Evenwel v. Abbott
Evenwel v. Abbott was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts in Texas. The plaintiffs, Sue Evenwel and Edward Pfenninger, argued that district populations ought to take into account only the number of registered or eligible voters residing within those districts as opposed to total population counts, which are generally used for redistricting purposes. Total population tallies include non-voting residents, such as immigrants residing in the country without legal permission, prisoners, and children. The plaintiffs alleged that this tabulation method dilutes the voting power of citizens residing in districts that are home to smaller concentrations of non-voting residents. The court ruled 8-0 on April 4, 2016, that a state or locality can use total population counts for redistricting purposes. The majority opinion was penned by Justice Ruth Bader Ginsburg.[153][154][155][5]
Harris v. Arizona Independent Redistricting Commission (2016)
Harris v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts that were created by the commission in 2012. The plaintiffs, a group of Republican voters, alleged that "the commission diluted or inflated the votes of almost two million Arizona citizens when the commission intentionally and systematically overpopulated 16 Republican districts while under-populating 11 Democrat districts." This, the plaintiffs argued, constituted a partisan gerrymander. The plaintiffs claimed that the commission placed a disproportionately large number of non-minority voters in districts dominated by Republicans; meanwhile, the commission allegedly placed many minority voters in smaller districts that tended to vote Democratic. As a result, the plaintiffs argued, more voters overall were placed in districts favoring Republicans than in those favoring Democrats, thereby diluting the votes of citizens in the Republican-dominated districts. The defendants countered that the population deviations resulted from legally defensible efforts to comply with the Voting Rights Act and obtain approval from the United States Department of Justice. At the time of redistricting, certain states were required to obtain preclearance from the U.S. Department of Justice before adopting redistricting plans or making other changes to their election laws—a requirement struck down by the United States Supreme Court in Shelby County v. Holder (2013). On April 20, 2016, the court ruled unanimously that the plaintiffs had failed to prove that a partisan gerrymander had taken place. Instead, the court found that the commission had acted in good faith to comply with the Voting Rights Act. The court's majority opinion was penned by Justice Stephen Breyer.[156][157][158]
Arizona State Legislature v. Arizona Independent Redistricting Commission (2015)
Arizona State Legislature v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2015. At issue was the constitutionality of the Arizona Independent Redistricting Commission, which was established by state constitutional amendment in 2000. According to Article I, Section 4 of the United States Constitution, "the Times, Places and Manner of holding Elections for Senators and Representatives shall be prescribed in each State by the Legislature thereof." The state legislature argued that the use of the word "legislature" in this context is literal; therefore, only a state legislature may draw congressional district lines. Meanwhile, the commission contended that the word "legislature" ought to be interpreted to mean "the legislative powers of the state," including voter initiatives and referenda. On June 29, 2015, the court ruled 5-4 in favor of the Arizona Independent Redistricting Commission, finding that "redistricting is a legislative function, to be performed in accordance with the state's prescriptions for lawmaking, which may include the referendum and the governor's veto." The majority opinion was penned by Justice Ruth Bader Ginsburg and joined by Justices Anthony Kennedy, Stephen Breyer, Elena Kagan, and Sonia Sotomayor. Chief Justice John Roberts and Justices Clarence Thomas, Antonin Scalia, and Samuel Alito dissented.[159][160][161][162]Trifectas and redistricting
In 34 of the states that conducted legislative elections in 2020, the legislatures themselves played a significant part in the subsequent redistricting process. The winner of eight of 2020's gubernatorial elections had veto authority over state legislative or congressional district plans approved by legislatures. The party that won trifecta control of a state in which redistricting authority rests with the legislature directed the process that produces the maps that will be used for the remainder of the decade. Trifecta shifts in the 2010 election cycle illustrate this point. In 2010, 12 states in which legislatures had authority over redistricting saw shifts in trifecta status. Prior to the 2010 elections, seven of these states were Democratic trifectas; the rest were divided governments. After the 2010 elections, seven of these states became Republican trifectas; the remainder either remained or became divided governments. The table below details these shifts and charts trifecta status heading into the 2020 election cycle.
| State | Primary redistricting authority | Pre-2010 trifecta status | Post-2010 trifecta status | Post-2018 trifecta status |
|---|---|---|---|---|
| Alabama | Legislature | Divided | Republican | Republican |
| Colorado | Congressional maps: legislature State legislative maps: politician commission |
Democratic | Divided | Democratic |
| Indiana | Legislature | Divided | Republican | Republican |
| Iowa | Legislature | Democratic | Divided | Republican |
| Maine | Legislature | Democratic | Republican | Democratic |
| Michigan | Legislature | Divided | Republican | Divided |
| New Hampshire | Legislature | Democratic | Divided | Divided |
| North Carolina | Legislature | Democratic | Divided | Divided |
| Ohio | Congressional maps: legislature State legislative maps: politician commission |
Divided | Republican | Republican |
| Oregon | Legislature | Democratic | Divided | Democratic |
| Pennsylvania | Congressional maps: legislature State legislative maps: politician commission |
Divided | Republican | Divided |
| Wisconsin | Legislature | Democratic | Republican | Divided |
2010 redistricting cycle
Congressional redistricting, 2010
Following the 2010 United States Census, Ohio lost two congressional seats. At the time of redistricting, Republicans held the governorship and both chambers of the Ohio General Assembly. On September 21, 2011, the legislature approved a congressional map, which was signed into law on September 26, 2011. Opponents threatened to subject the map to a veto referendum. In Ohio, legislation that is not related to spending may be subjected to a veto referendum if it does not pass the legislature by a two-thirds vote. Democratic opponents of the maps commenced a petition drive to put the issue before voters in the next statewide election. This proved unnecessary, however, as a revised congressional map passed the state legislature on December 14, 2011, and was signed into law the next day.[163][164]
A constitutional amendment that would have established an independent congressional redistricting commission was defeated by voters on November 6, 2012.
State legislative redistricting, 2010
On September 28, 2011, the politician redistricting commission approved new state legislative district maps. Although these maps were subject to litigation, they were ultimately upheld.[163]
See also
- Redistricting in Ohio after the 2010 census
- Redistricting in Ohio
- State-by-state redistricting procedures
- Majority-minority districts
External links
- Search Google News for this topic
- All About Redistricting
- Dave's Redistricting
- FiveThirtyEight, "What Redistricting Looks Like In Every State"
- National Conference of State Legislatures, "Redistricting Process"
- FairVote, "Redistricting"
Footnotes
- ↑ Dayton Daily News, "Ohio Redistricting Commission approves new U.S. House map on another party-line vote," March 2, 2022
- ↑ 13ABC, "Ohio Supreme Court makes final judgement on Congressional map challenges," March 18, 2022
- ↑ WTVG, "Ohio to redraw Congressional map for 2026 election," December 18, 2024
- ↑ Ohio Legislative Budget Office, "Redistricting in Ohio: Members Brief," April 19, 2024
- ↑ 5.0 5.1 Associated Press, "Bipartisan Ohio commission unanimously approves new maps that favor Republican state legislators," September 27, 2023 Cite error: Invalid
<ref>tag; name "ap" defined multiple times with different content - ↑ Ohio Capital Journal, "Ohio Redistricting Commission adopts sixth version of Statehouse maps with bipartisan support," September 27, 2023
- ↑ 21 WFMJ, "Newly enacted district maps challenged by voting rights groups," October 5, 2023
- ↑ 8.0 8.1 8.2 AP, "Ohio Supreme Court dismisses 3 long-running redistricting lawsuits against state legislative maps," November 28, 2023
- ↑ Ohio Capital Journal, "Ohio Supreme Court dismisses redistricting challenge, leaving Statehouse maps in place," November 28, 2023
- ↑ Neiman, et al v. LaRose, et al," September 5, 2023
- ↑ 21 WFMJ, "Newly enacted district maps challenged by voting rights groups," October 5, 2023
- ↑ Associated Press, "Bipartisan Ohio commission unanimously approves new maps that favor Republican state legislators," September 27, 2023
- ↑ Ohio Capital Journal, "Ohio Redistricting Commission adopts sixth version of Statehouse maps with bipartisan support," September 27, 2023
- ↑ Neiman, et al v. LaRose, et al," September 5, 2023
- ↑ Neiman, et al v. LaRose, et al," September 5, 2023
- ↑ Supreme Court of the United States, "Order List (6/30/2023)," accessed September 8, 2023
- ↑ 17.0 17.1 The Columbus Dispatch, "Gov. DeWine approves congressional map over objections of voting rights groups, Democrats," November 20, 2021
- ↑ The Columbus Dispatch, "Democrats won't support Republican-drawn Ohio congressional districts, limiting map to four years," November 16, 2021
- ↑ WHIO, "Ohio Congressional map heads to Governor; Clark County would be divided," November 19, 2021
- ↑ 20.0 20.1 20.2 20.3 Court News Ohio, "Congressional Map Ruled Unconstitutional," January 14, 2022
- ↑ WKSU, "Legislative leaders send Congressional mapmaking back to Ohio Redistricting Commission," February 9, 2022
- ↑ Neiman, et al v. LaRose, et al," September 5, 2023
- ↑ Supreme Court of the United States, "Order List (6/30/2023)," accessed September 8, 2023
- ↑ Dayton Daily News, "Ohio Redistricting Commission approves new U.S. House map on another party-line vote," March 2, 2022
- ↑ 13ABC, "Ohio Supreme Court makes final judgement on Congressional map challenges," March 18, 2022
- ↑ Cleveland.com, "Ohio legislature passes congressional redistricting plan giving Republicans a significant advantage," November 18, 2021
- ↑ Political predecessor districts are determined primarily based on incumbents and where each chose to seek re-election.
- ↑ Daily Kos Elections, "Daily Kos Elections 2020 presidential results by congressional district (old CDs vs. new CDs)," accessed May 12, 2022
- ↑ Cleveland.com, "Ohio is about to hold elections for unconstitutional congressional and legislative districts. Here’s how it happened," October 9, 2022
- ↑ Ohio Capital Journal, "Ohio Redistricting Commission adopts sixth version of Statehouse maps with bipartisan support," September 27, 2023
- ↑ WCBE, "Ohio Redistricting Commission unanimously approves 6th version of House and Senate maps," September 27, 2023
- ↑ WFMJ, "Newly enacted district maps challenged by voting rights groups," October 5, 2023
- ↑ Ohio Capital Journal, "Ohio Supreme Court dismisses redistricting challenge, leaving Statehouse maps in place," November 28, 2023
- ↑ Supreme Court of Ohio, "League of Women Voters v. Ohio Redistricting Commission," accessed September 11, 2024
- ↑ 35.0 35.1 35.2 News 5 Cleveland, "Trump-appointed federal court judges end Ohio's redistricting battle, side with GOP," May 30, 2022
- ↑ 36.0 36.1 36.2 Cleveland.com, "Ohio Redistricting Commission approves new state legislative maps that maintain Republican supermajority despite anti-gerrymandering reforms," September 16, 2021
- ↑ Ohio Legislative Budget Office, "Redistricting in Ohio: Members Brief," April 19, 2024
- ↑ Court News Ohio, "New Ohio Legislative District Maps Unconstitutional," January 12, 2022
- ↑ 39.0 39.1 39.2 39.3 Court News Ohio, "Revised Ohio House and Senate Maps Still Unconstitutional and Must Be Re-Drawn," February 7, 2022
- ↑ Ohio Supreme Court, "League of Women Voters of Ohio v. Ohio Redistricting Comm." February 7, 2022
- ↑ 41.0 41.1 41.2 41.3 Ohio Capital Journal, "Redistricting commission punts again, defies court order," February 17, 2022
- ↑ Cleveland.com, "Ohio Redistricting Commission approves state legislative map plan, again," February 25, 2022
- ↑ 43.0 43.1 43.2 43.3 Court News Ohio, "Third Attempt at State House and Senate Maps Unconstitutional," March 16, 2022
- ↑ Tribune Chronicle, "Tue. 11:38 a.m.: Ohio mapmakers to meet on 4th set of statehouse districts," March 22, 2022
- ↑ WOSU, "Ohio Redistricting Commission will bring in two consultants to develop new Statehouse maps," March 22, 2022
- ↑ Cleveland.com, "Republicans on Ohio Redistricting Commission approve slightly revised version of rejected map, abandon bipartisan plan," March 28, 2022
- ↑ 47.0 47.1 47.2 47.3 Cleveland.com, "Ohio Supreme Court again orders redistricting commission members to explain why they shouldn’t be held in contempt," March 30, 2022
- ↑ 48.0 48.1 48.2 48.3 Statehouse News Bureau, "Ohio Supreme Court rejects fourth set of state legislative district maps," April 14, 2022
- ↑ Spectrum News 1, "Federal court decides to not interfere with legislative map redistricting, yet," April 20, 2022
- ↑ Ohio Capital Journal, "Ohio Redistricting Commission resubmits maps already rejected as illegal by supreme court," May 5, 2022
- ↑ 51.0 51.1 51.2 51.3 Oxford Observer, "Redistricting Commission adopts maps previously rejected by Ohio Supreme Court," May 6, 2022
- ↑ KSTP, "Ohio’s high court rejects latest GOP-drawn Statehouse maps," May 25, 2022
- ↑ Ohio Capital Journal, "Federal court implements Statehouse maps twice declared unconstitutional by Ohio Supreme Court," May 27, 2022
- ↑ Statehouse News Bureau, "Republican Senate President Defends Statehouse District Maps Critics Blast As Gerrymandered And Unfair," September 16, 2021
- ↑ The Ohio Senate, "Redistricting Commission Approves Four Year Maps for General Assembly," September 16, 2021
- ↑ News5Cleveland, "Reaction pours in after Ohio Redistricting Commission votes on party lines for 4-year maps," September 16, 2021
- ↑ Spectrum News 1, "Ohio sets date for 1st redistricting commission meeting," August 2, 2021
- ↑ Dayton Daily News, "Legislators likely to miss deadline for new congressional map," September 25, 2021
- ↑ Marietta Times, "Redistricting commission starts work under rushed deadline," August 10, 2021
- ↑ Cleveland.com, "Gov. Mike DeWine calls first meeting of Ohio redistricting panel," August 2, 2021
- ↑ Marietta Times, "Redistricting commission starts work under rushed deadline," August 10, 2021
- ↑ Ohio Legislature, "Joint Committee on Redistricting," accessed November 9, 2021
- ↑ Marion Star, "Ohio Redistricting Commission, set to miss first deadline, can't agree on who draws maps," August 31, 2021
- ↑ Cleveland.com, "Ohio Republicans unveil new state legislative maps preserving GOP Statehouse supermajority, despite anti-gerrymandering rules," September 9, 2021
- ↑ Fox 8, "Democrats present Ohio legislative maps proposal," February 11, 2022
- ↑ 66.0 66.1 The Columbus Dispatch, "'An insult to democracy': Ohio Republicans' redistricting plan panned soon after release," September 9, 2021
- ↑ Newark Advocate, "Ohio Redistricting: See Democratic lawmakers' counteroffer on legislative maps," September 13, 2021
- ↑ Ohio Capital Journal, "Senate Dems propose congressional map," September 30, 2021
- ↑ Ohio Senate, "Sen. Sykes, Senate Democrats Present Amended Congressional Map Proposal," November 10, 2021
- ↑ Ohio Capital Journal, "GOP releases proposed congressional maps preserving their huge advantage," November 4, 2021
- ↑ Ohio Capital Journal, "Ohio House Dems submit congressional redistricting maps," November 9, 2021
- ↑ Cleveland.com, "Ohio Republicans introduce final congressional redistricting proposal, aiming to give it first set of approvals today," November 15, 2021
- ↑ United States Census Bureau, "Apportionment," accessed July 11, 2018
- ↑ United States Census Bureau, "2020 Census Apportionment Results Delivered to the President," April 26, 2021
- ↑ United States Census Bureau, "2020 Census Operational Plan: Executive Summary," December 2015
- ↑ United States Census Bureau, "Census Bureau Statement on Redistricting Data Timeline," February 12, 2021
- ↑ 77.0 77.1 Office of the Attorney General of Ohio, "AG Yost Secures Victory for Ohioans in Settlement with Census Bureau Data Lawsuit," May 25, 2021
- ↑ 78.0 78.1 U.S. Census Bureau, "U.S. Census Bureau Statement on Release of Legacy Format Summary Redistricting Data File," March 15, 2021
- ↑ U.S. Census Bureau, "Decennial Census P.L. 94-171 Redistricting Data," accessed August 12, 2021
- ↑ United States Census Bureau, "Census Bureau Delivers 2020 Census Redistricting Data in Easier-to-Use Format," September 16, 2021
- ↑ Ohio Capital Journal, "New congressional suit challenges redistricting map," March 22, 2022
- ↑ Ohio Supreme Court, "Neiman v. LaRose," accessed March 22, 2022
- ↑ Chillicothe Gazette, "Ohio Supreme Court won't review congressional map until after May 3 primary," March 29, 2022
- ↑ 84.0 84.1 84.2 The Columbus Dispatch, "Redistricting: Ohio Supreme Court rejects congressional map used in May, orders new one," July 19, 2022
- ↑ 85.0 85.1 85.2 Neiman, et al v. LaRose, et al," July 19, 2022
- ↑ Supreme Court of the United States, "Order List (6/30/2023)," accessed September 8, 2023
- ↑ Democracy Docket, " Ohio Supreme Court Dismisses Lawsuits Over Congressional Map ," September 7, 2023
- ↑ The Columbus Dispatch, "Lawsuit asks federal judges to adopt legislative maps rejected by Ohio Supreme Court," February 18, 2022
- ↑ Cleveland.com, "Federal judge says he’s staying out of Ohio’s redistricting fight, for now," March 14, 2022
- ↑ Statehouse News Bureau, "Federal judges will review a challenge to Ohio's redistricting process," March 18, 2022
- ↑ The Columbus Dispatch, "With May 3 out for legislative candidates, judges weigh options for new primary date, map," March 30, 2022
- ↑ Spectrum News 1, "Federal court decides to not interfere with legislative map redistricting, yet," April 20, 2022
- ↑ Democracy Docket, "Simon v. DeWine," November 30, 2021
- ↑ Cleveland.com, "Federal judge pauses federal redistricting lawsuit to await decision from Ohio Supreme Court," January 13, 2022
- ↑ 95.0 95.1 95.2 95.3 Court News Ohio, "New Ohio Legislative District Maps Unconstitutional," January 12, 2022
- ↑ Crossroads Today, "Voter rights groups sue over Ohio GOP’s congressional map," December 2, 2021
- ↑ Ohio Supreme Court, "League of Women Voters of Ohio v. DeWine," accessed December 2, 2021
- ↑ Ohio Supreme Court, "Entry," December 6, 2021
- ↑ 99.0 99.1 99.2 99.3 Ohio Supreme Court, "SLIP OPINION NO. 2022-OHIO-89," accessed January 14, 2022
- ↑ 100.0 100.1 13ABC, "Ohio Supreme Court makes final judgement on Congressional map challenges," March 18, 2022
- ↑ The Columbus Dispatch, "Redistricting: Eric Holder-backed lawsuit challenges Ohio congressional map," November 22, 2021
- ↑ National Redistricting Action Fund, "Adams v. DeWine," accessed November 23, 2021
- ↑ Ohio Supreme Court, "Entry," December 3, 2021
- ↑ Ohio Capital Journal, "Ohio Supreme Court dismisses redistricting challenge, leaving Statehouse maps in place," November 28, 2023
- ↑ WOSU, "Third Lawsuit Filed Over Ohio's New Legislative Maps," September 28, 2021
- ↑ SCRIBD, "Ohio Organizing Collaborative, et al. v. Ohio Redistricting Commission, et al.," accessed September 28, 2021
- ↑ 107.0 107.1 107.2 107.3 107.4 107.5 Supreme Court of Ohio, "SLIP OPINION NO. 2022-OHIO-65," accessed January 13, 2022
- ↑ 108.0 108.1 108.2 Ohio Capital Journal, "Groups say Ohio legislative maps still violate constitution," January 27, 2022
- ↑ The Brennan Center for Justice, "OBJECTIONS OF PETITIONERS THE OHIO ORGANIZING COLLABORATIVE, ET AL.," January 25, 2022
- ↑ 110.0 110.1 110.2 Ohio Supreme Court, "League of Women Voters of Ohio v. Ohio Redistricting Comm. (Slip Opinion)," accessed February 8, 2022
- ↑ 111.0 111.1 111.2 NBC 4i, "Ohio Redistricting Commission has until Wednesday to explain failure to draw maps," February 18, 2022
- ↑ 112.0 112.1 112.2 WDTN, "Redistricting Commission responds to Ohio Supreme Court over unfinished maps," February 23, 2022
- ↑ 113.0 113.1 113.2 Associated Press, "Ohio political mapmakers awaiting fate of high court meeting," February 25, 2022
- ↑ 114.0 114.1 114.2 ABC 13, "Ohio Supreme Court postpones contempt hearing for Redistricting Commission," February 25, 2022
- ↑ 115.0 115.1 115.2 KSTP, "Ohio’s high court rejects latest GOP-drawn Statehouse maps," May 25, 2022
- ↑ Ohio Capital Journal, "Ohio Supreme Court dismisses redistricting challenge, leaving Statehouse maps in place," November 28, 2023
- ↑ 117.0 117.1 Cite error: Invalid
<ref>tag; no text was provided for refs nameddddismiss - ↑ Spectrum News 1, "Second lawsuit filed against Ohio Redistricting Commission," Sept 26, 2021
- ↑ SCRIBD, "Bennett OH 09 24 2021," accessed September 28, 2021
- ↑ Ohio Supreme Court, "PETITIONERS’ OBJECTIONS," January 25, 2022
- ↑ Statehouse News Bureau, "Lawsuit Filed Over Ohio House, Senate Maps That Keep Republican Supermajorities," September 23, 2021
- ↑ ACLU Ohio, "ACLU OF OHIO, LWV-OHIO, AND APRI LAUNCH LEGAL CHALLENGE OVER OHIO PARTISAN GERRYMANDERING," September 23, 2021
- ↑ ACLU Ohio, "League of Women Voters of Ohio v. Ohio Redistricting Commission," accessed September 28, 2021
- ↑ Ohio Supreme Court, "PETITIONERS’ OBJECTION TO THE OHIO REDISTRICTING COMMISSION’S REVISED MAP," January 25, 2022
- ↑ United States District Court for the Southern District of Ohio, "Ohio v. Coggins: Complaint for Injunctive and Mandamus Relief," February 25, 2021
- ↑ United States District Court for the Southern District of Ohio, "Ohio v. Coggins: Entry and Order Denying Plaintiff's Motion for Preliminary Injunction," March 24, 2021
- ↑ Justia, "State of Ohio v. Gina Raimondo, No. 21-3294 (6th Cir. 2021)," accessed May 25, 2021
- ↑ Ballot Access News, "Sixth Circuit Sets Oral Argument in Ohio’s Case to Force Census Bureau to Furnish Data Sooner," May 8, 2021
- ↑ United States Court of Appeals for the Sixth Circuit, "Ohio v. Raimondo: Per Curiam," May 18, 2021
- ↑ The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
- ↑ Brookings, "Redistricting and the United States Constitution," March 22, 2011
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
- ↑ The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
- ↑ 135.0 135.1 135.2 135.3 135.4 135.5 135.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
- ↑ 136.0 136.1 136.2 136.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
- ↑ All About Redistricting, "Who draws the lines?" accessed June 19, 2017
- ↑ All About Redistricting, "Why does it matter?" accessed April 8, 2015
- ↑ Encyclopædia Britannica, "Gerrymandering," November 4, 2014
- ↑ Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
- ↑ The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
- ↑ The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
- ↑ United States District Court for the District of South Carolina, Columbia Division, "South Carolina State Conference of the NAACP, et al. v. Alexander," January 6, 2023
- ↑ Supreme Court of the United States, "Alexander, et al. v. The South Carolina State Conference of the NAACP, et al.," February 17, 2023
- ↑ SCOTUSblog, "Alexander v. South Carolina State Conference of the NAACP," accessed July 21, 2023
- ↑ SCOTUSblog, "Justices will hear case that tests power of state legislatures to set rules for federal elections," June 30, 2022
- ↑ U.S. Supreme Court, “Moore, in his Official Capacity as Speaker of The North Carolina House of Representatives, et al. v. Harper et al.," "Certiorari to the Supreme Court of North Carolina,” accessed June 16, 2023
- ↑ SCOTUSblog.org, "Supreme Court upholds Section 2 of Voting Rights Act," June 8, 2023
- ↑ Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
- ↑ Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
- ↑ Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
- ↑ Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
- ↑ The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
- ↑ The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
- ↑ SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
- ↑ SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
- ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
- ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
- ↑ The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
- ↑ The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
- ↑ United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
- ↑ The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
- ↑ 163.0 163.1 Cite error: Invalid
<ref>tag; no text was provided for refs namedohloyola - ↑ Barone, M. & McCutcheon, C. (2013). The almanac of American politics 2014 : the senators, the representatives and the governors : their records and election results, their states and districts. Chicago, IL: University of Chicago Press.
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