In re 2003 Legislative Apportionment of the House of Representatives

2003 ME 81, 827 A.2d 810
CourtSupreme Judicial Court of Maine
DecidedJuly 2, 2003
StatusPublished
Cited by4 cases

This text of 2003 ME 81 (In re 2003 Legislative Apportionment of the House of Representatives) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re 2003 Legislative Apportionment of the House of Representatives, 2003 ME 81, 827 A.2d 810 (Me. 2003).

Opinion

SAUFLEY, Chief Justice.

[¶ 1] As is required by the Maine Constitution, the 121st Maine Legislature undertook the reapportionment of the House of Representatives in, January 2003. Ultimately, a reapportionment plan was approved by the House and the Senate and was signed into law by Governor John E. Baldacci on April 15, 2003. Two challenges were filed with the Supreme Judicial Court, one challenging the plan’s composition of the Portland area districts, including Districts 114, 115, 117, and 120, and the other challenging the plan’s composition of District 36, comprising several towns and islands in Hancock and Knox Counties. We conclude that the Legislature’s plan complies with both constitutional and statutory requirements, and we do not sustain the challenges.

I. BACKGROUND

[¶ 2] Pursuant to Article IV, Part First, Section 2 of the Maine Constitution, “[t]he Legislature which convenes in 1983 and every 10th year thereafter shall cause the State to be divided into districts for the choice of one Representative for each district.” Accordingly, in January 2003, the 121st Legislature established a bipartisan Apportionment Commission to consider the composition of the Maine House of [812]*812Representatives.1 See ME. CONST, art. IV, pt. 3, § 1-A.2 The Commission heard from members of the public and reviewed various plans. See id.' Because the population of the State of Maine had changed both regionally and as to total population over the last ten years,3 the Commission was required to change the existing districts to comply with constitutional requirements of population parity.

[¶ 3] In April 2003, the Commission submitted its plan for redistricting the House of Representatives to the full Legislature.4 See id. art. IV, pt. 1, § 3. The House accepted that plan by passing L.D. 1555, “An Act to Reapportion the House Legislative Districts” by the required two-thirds votes on April 10, 2003. See id. The Senate passed the House Plan by the required two-thirds votes on April 15, 2003. See id. The House Plan was finally approved and signed by Governor Baldacci on April 15, 2003, as required by the Maine Constitution. See id.; id. art. IV, pt. 3, § 2; P.L.2003, ch. 44.

[¶ 4] The Green Independent Party, the Cumberland County Green Independent Party, and two individual citizens, Mary L. Donnelly and Benjamin Meiklejohn (collectively referred to as the Portland challengers), filed a challenge to the House Plan, contending that, with regard to the Portland districts, the plan fails to satisfy the compactness and contiguity requirements mandated by the Maine Constitution in House Districts 114, 115, 117, and 120. ME. CONST, art. IV, pt. 1, § 2; see also 21-A M.R.S.A. § 1206-A (Supp.2002). [813]*813The Portland challengers argue that the districts were unusually shaped and were created to avoid incumbent election match-ups, at the expense of the only State Representative of the Green Independent Party-

[¶ 5] The second challenge was presented by Douglas R. Johnson, who challenges the House Plan’s treatment of District 36 (comprising islands and towns in Hancock and Knox Counties). Mr. Johnson contends that the configuration of the district violates the compactness and contiguity requirements of the Maine Constitution. Johnson alleges that District 36 is not compact because travel among the island communities therein requires extensive travel by car or boat, and that District 36 is not contiguous because the communities are separated by large stretches of water.

[¶ 6] The Department of the Attorney General (representing the Legislature), the Maine Democratic Party, the Speaker of the House, Patrick Colwell, and House Republican Leader, Joseph Bruno, assert that the House Plan satisfies all constitutional requirements. Specifically, they state that the primary goal of the plan was to realign districts according to population shifts. In addition, the plan was devised to minimize incumbent election match-ups, to use major roads as boundaries, and, whenever possible, to maintain communities of interest.

II. DISCUSSION

A. Jurisdiction

[¶ 7] Although the challenges come to the Court in a posture that is similar initially to that of an appeal, the Maine Constitution provides that we address this as an original action. “The Supreme Judicial Court shall have original jurisdiction to hear any challenge to an apportionment law enacted by the Legislature, as registered by any citizen or group thereof. If any challenge is sustained, the Supreme Judicial Court shall make the apportionment.” ME. CONST, art. IV, pt. 1, § 3. All challengers and supporters of the House Plan were invited to present written argument, and to submit maps and other population and geographical information. A public hearing was held at which the various positions were presented.

B. Standard of Review

[¶ 8] When the Legislature reaches agreement on a decennial reapportionment, the resulting law establishing the new districts is entitled to a strong presumption of validity. See In re 1983 Legislative Apportionment of House, Senate, & Cong. Dists., 469 A.2d 819, 827 (Me.1983). The Legislature is the branch of government that is required in the first instance to reconcile traditional state policies within the constitutional mandates governing the reapportionment of state legislative and United States Congressional districts. Id. A duly enacted apportionment plan is not rendered unconstitutional because a resourceful challenger, or a court, can create a better plan. See id. at 828. Accordingly, the pivotal question is not whether the Legislature enacted the best plan, but whether the enacted plan is constitutional. Id.

[¶ 9] The challengers have a heavy burden of demonstrating that the apportionment is unconstitutional. See id. at 830. We will not alter the Legislature’s chosen apportionment unless the Legislature failed to comply with constitutional norms, see Kareher v. Daggett, 462 U.S. 725, 740, 103 S.Ct. 2653, 77 L.Ed.2d 133 (1983), or was motivated by impermissible discriminatory intent in making the compromises necessary to harmonize state and [814]*814federal standards, In re 1983 Legislative Apportionment, 469 A.2d at 827.

C. Population Parity

[¶ 10] The foremost principle guiding reapportionment is the requirement that each person receive equal access to representation. See Chapman v. Meier, 420 U.S. 1, 22, 95 S.Ct. 751, 42 L.Ed.2d 766 (1975). Any apportionment plan must comply with Federal Constitutional mandates, including the “one person, one vote” principal of the Equal Protection Clause of the Fourteenth Amendment. See id. at 28, 95 S.Ct. 751 (acknowledging “that some leeway in the equal population requirement should be afforded states in devising their legislative reapportionment plans”). Thus, state legislatures must “‘make an honest and good faith effort to construct districts ... as nearly of equal population as is practicable.’ ”

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2003 ME 81, 827 A.2d 810, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-2003-legislative-apportionment-of-the-house-of-representatives-me-2003.