Wisconsin Business Leaders for Democracy v. Wisconsin Elections Commission

2025 WI 52
CourtWisconsin Supreme Court
DecidedNovember 25, 2025
Docket2025XX001330
StatusPublished

This text of 2025 WI 52 (Wisconsin Business Leaders for Democracy v. Wisconsin Elections Commission) is published on Counsel Stack Legal Research, covering Wisconsin Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wisconsin Business Leaders for Democracy v. Wisconsin Elections Commission, 2025 WI 52 (Wis. 2025).

Opinion

2025 WI 52

WISCONSIN BUSINESS LEADERS FOR DEMOCRACY ET AL., Plaintiffs, v. WISCONSIN ELECTIONS COMMISSION ET AL., Defendants,

GLENN GROTHMAN ET AL., Intervening Defendants.

No. 2025XX1330 Filed November 25, 2025

The Court entered the following order on this date:

On July 10, 2025, this court received written notice from the Dane County Clerk of Courts of the filing of a summons and complaint on July 8, 2025, by Wisconsin Business Leaders for Democracy and a group of individual voters (collectively, “WBLD”) against the Wisconsin Elections Commission et al. (collectively, “WEC”). The complaint alleges that Wisconsin’s current congressional map violates the Wisconsin Constitution in various respects. The Dane County Clerk of Courts enclosed a copy of the summons and complaint in its July 10, 2025 written notice to this court. This court opened miscellaneous Case No. 2025XX1330 to receive these filings. WIS. BUSINESS LEADERS FOR DEMOCRACY v. WIS. ELECTIONS COMM’N Order of the Court In its letter, the Dane County Clerk of Courts office stated that it was notifying this court of the filing of WBLD’s summons and complaint pursuant to WIS. STAT. § 801.50(4m), which states that “[n]ot more than 5 days after an action to challenge the apportionment of a congressional or state legislative district is filed, the clerk of courts for the county where the action is filed shall notify the clerk of the supreme court of the filing.” This section further states that “[v]enue of an action to challenge the appointment of any congressional or state legislative district shall be as provided in s. 751.035.” WISCONSIN STAT. § 731.035(1) states that “[u]pon receiving notice under s. 801.50(4m), the supreme court shall appoint a panel consisting of 3 circuit court judges to hear the matter. The supreme court shall choose one judge from each of 3 circuits and shall assign one of the circuits as the venue for all hearings and filings in the matter.”

On September 25, 2025, this court entered an order requiring the parties to submit simultaneous briefs and response briefs addressing “whether WBLD’s complaint filed in the circuit court constitutes ‘an action to challenge the apportionment of a congressional or state legislative district’ under WIS. STAT. § 801.50(4m).” The court received and granted motions by Billie Johnson and other individual voters (collectively, “Johnson”) and the Wisconsin Legislature for leave to file non-party briefs amicus curiae. The court also received and granted a motion to intervene filed by a group of Congressmen and individual voters (collectively, the “Congressmen”). The briefing subsequently received by the court may be briefly summarized as follows:

The WBLD plaintiffs argue that their complaint clearly constitutes “an action to challenge the apportionment of any congressional or state legislative district” for purposes of WIS. STAT. § 801.50(4m). This is so given that, in various cases over many years’ time, this court has used the terms “redistricting,” “apportionment,” and “reapportionment” interchangeably to mean redrawing Wisconsin’s congressional and state legislative districts so as to comply with state or federal law. The court’s use of these terms interchangeably comports with Wisconsin Constitution Article IV, Section 3, which labels the state legislative redistricting process “Apportionment” in its title and describes the legislature’s task as to “apportion and district” anew. Moreover, cases interpreting an analogous federal statute, 28 U.S.C. § 2284, which requires appointment of three-judge panels to hear

2 WIS. BUSINESS LEADERS FOR DEMOCRACY v. WIS. ELECTIONS COMM’N Order of the Court “apportionment” challenges in federal courts, consistently use the terms “apportionment” and “redistricting” interchangeably. Given the above, the WBLD plaintiffs argue, their complaint plainly falls within the scope of § 801.50(4m), thus requiring this court to appoint a three-judge panel and designate a circuit court venue pursuant to § 751.035.

The Congressmen, the Legislature, and the amici generally argue that WBLD’s complaint does not fall within the scope of WIS. STAT. § 801.50(4m) because the complaint is not an “apportionment” challenge, which they define narrowly as a challenge to the distribution of legislative seats among districts. WBLD’s complaint is instead a “redistricting” challenge, which they define narrowly as a challenge to district boundaries. In their view, the non-synonymous nature of the terms is confirmed by the Wisconsin Constitution, which uses the terms “apportion” and “district” in a single section (WIS. CONST. ART. IV, § 3), indicating that the terms have distinct meanings. Moreover, these parties argue, “apportionment” refers only to legislative action, not the remedial judicial action that this court took in Johnson v. WEC, 2022 WI 14, 400 Wis. 2d 626, 971 N.W.2d 402 (“Johnson II”) of adopting Wisconsin’s current congressional map. Because WBLD’s lawsuit is not an “apportionment” challenge, these parties submit, the court should not appoint a three-judge panel. Instead, the court should employ its superintending authority and dismiss WBLD’s complaint, as the suit constitutes an improper collateral attack on Johnson II that a lower court is in no position to adjudicate.

The defendants—WEC, its members, and its administrator—filed a statement explaining that it takes no position on the question posed.

We conclude that WBLD’s complaint does constitute “an action to challenge the apportionment of any congressional or state legislative district” for purposes of WIS. STAT. § 801.50(4m). We acknowledge, as noted by the parties, that in Jensen v. Wisconsin Elections Bd., 2002 WI 13, 249 Wis. 2d 706, 639 N.W.2d 537, we stated in a footnote, without citation, that “[r]eapportionment is the allocation of seats in a legislative body where the district boundaries do not change but the number of members per district does (e.g., allocation of congressional seats among established districts, that is, the states); redistricting is the drawing of new political boundaries[.]” Id., ¶5 n.2. But this statement did not address the meaning of § 801.50(4m)—a

3 WIS. BUSINESS LEADERS FOR DEMOCRACY v. WIS. ELECTIONS COMM’N Order of the Court statute that did not exist until nearly 10 years after the Jensen decision. Were we to view Jensen as dispositive of the meaning of the term “apportionment” in § 801.50(4m)—such that here, the term would refer only to the allocation of congressional seats to Wisconsin—it is difficult to conceive of any state-court “action to challenge the apportionment of any congressional . . . district” to which § 801.50(4m) would apply, as “apportionment” in that sense occurs only at the federal level, not the state level. See U.S. CONST. art. I, § 2, cl. 3. We decline to adopt such a cramped reading of the statute, particularly given that neither we nor other courts have consistently used the term “apportionment” in such a limited sense. See, e.g., Jensen, ¶5 n.2 (noting that “[t]he cases . . . sometimes use the terms ‘reapportionment’ and ‘redistricting’ interchangeably”); see also Shapiro v. McManus, 577 U.S. 39, 43 (2015) (noting, in the context of a partisan gerrymandering challenge to a state’s congressional redistricting plan, that “[n]obody disputes that the present suit is ‘an action. . . challenging the constitutionality of the apportionment of congressional districts’” for purposes of 28 U.S.C. § 2284(a)). We also reject as unsupported the suggestion in the briefing that “apportionment” refers only to legislative action, not judicial action. See Growe v.

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Bluebook (online)
2025 WI 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wisconsin-business-leaders-for-democracy-v-wisconsin-elections-commission-wis-2025.