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Shapiro v. McManus

Facts of the Case

Provided by Oyez

In 2011, the Maryland General Assembly enacted a redistricting plan based on the results of the 2010 census. Several of the districts consisted of de-facto non-contiguous segments—discrete segments that would be wholly unconnected but for one or two narrow strips connecting the two—often with largely inconsistent demographics between the two large segments. The plaintiffs were a group of citizens who sued the Chair of the Maryland State Board of Elections (Board) and the State Administrator of the Board and argued that the new districting plan violated their rights to political association and equal representation under the First and Fourteenth Amendments. The defendants moved to dismiss the suit under Federal Rule of Civil Procedure 12(b)(6), which requires that a complaint be plausible on its face and enable the court to draw a reasonable inference of misconduct. The district court granted the motion to dismiss and held that the complaint did no more than imply the mere possibility of misconduct. Therefore, the case did not go before a three-judge panel, as the Three-Judge Court Act requires for cases dealing with congressional districts unless the claim is determined to be insubstantial. The U.S. Court of Appeals for the Fourth Circuit affirmed the dismissal.

Questions

  1. May a single-judge district court determine that a claim governed by the Three-Judge Court Act need not be heard by a three-judge panel, not because the claim is insubstantial, but because the complaint did not state a claim under Federal Rule of Civil Procedure 12(b)(6)?

Conclusions

  1. Justice Antonin Scalia delivered the opinion for the unanimous Court, which held that a claim covered by the Three-Judge Court Act must be heard by a three-judge panel. The text of the Act requires that any covered claim be heard by a three-judge panel and does not grant an individual district court judge the discretion to decide otherwise. A district court judge may only decide whether the claim is one that the Three-Judge Court Act covers and may not make any judgments on the merit of the case. The Court also held that the question of whether a claim is “insubstantial” is a jurisdictional one addressing whether the district court can hear the case, and not a question of whether the lawsuit failed to state a claim for which relief can be granted. Especially for constitutional claims, the “insubstantial” barrier is a high one, and the claim in this case should not have been dismissed as insubstantial.