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League of Women Voters of Florida v. Detzner, 172 So.3d 363, 40 Fla. L. Weekly S432

Facts

In February 2012, the Florida Legislature approved a plan apportioning the state's twenty-seven congressional districts based on the 2010 Census. Following the passage of the Fair Districts Amendment in 2010, which aimed to eliminate partisan gerrymandering, two groups of plaintiffs challenged the validity of the redistricting plan, asserting that it was drawn with the intent to favor the Republican Party and its incumbents. The trial court found that the redistricting process was tainted by improper partisan intent, leading to the current appeal.

In February 2012, the Florida Legislature approved a plan apportioning the state's twenty-seven congressional districts based on the 2010 Census.

Issue

Whether the Florida Legislature had an improper intent prohibited by the Fair Districts Amendment in drawing the congressional redistricting plan.

Rule

The Fair Districts Amendment prohibits the drawing of congressional districts with the intent to favor or disfavor a political party or an incumbent, and the burden shifts to the Legislature to justify its decisions once unconstitutional intent is found.

Analysis

The court applied the Fair Districts Amendment by examining the actions and statements of legislators and staff, concluding that the evidence supported the trial court's finding of unconstitutional partisan intent. The court emphasized that the trial court should have analyzed the redistricting plan as a whole rather than focusing solely on individual districts, and that the burden to justify the map shifted to the Legislature once unconstitutional intent was established.

Conclusion

The Supreme Court affirmed the trial court's finding of unconstitutional intent but reversed its order regarding the remedial redistricting plan, directing the Legislature to redraw specific districts affected by the unconstitutional intent.

Who won?

The challengers prevailed in establishing that the redistricting plan was drawn with unconstitutional partisan intent, as the court found sufficient evidence to support this claim.

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