Filed Date: 1982
Closed Date: Oct. 4, 1982
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This is a lawsuit about apportionment of state legislative districts. Several individual plaintiffs filed this lawsuit in the US District Court for the District of New Mexico in 1982 against various New Mexico government officials, including the Governor and Secretary of State. The plaintiffs were represented by various organizations, including the ACLU, the Southwest Voter Registration Education Project, Southern New Mexico Legal Services, and the National Indian Youth Council. The United States later intervened as a plaintiff, as did the Democratic and Republican parties.
The plaintiffs sued under 42 USC § 1983, alleging that districts adopted by the New Mexico legislature in 1982 for future state house and senate elections violated the Fourteenth Amendment's Equal Protection Clause. The "one-person-one-vote principle," a component of equal protection, requires electoral districts to contain approximately the same number of people to ensure equal representation. Because this case challenged the constitutionality of state legislative districts, it was heard by a three-judge panel under 28 USC § 2284. The judges assigned were Chief Circuit Judge Oliver Seth and District Judges Edwin L. Mechem and Guerrero Burciaga. This case appears to have resulted from the consolidation of various dockets (82-cv-00067, 82-cv-00084, 82-cv-00180, and 82-cv-00219).
On April 8, 1982, the court ruled for the plaintiffs, holding that New Mexico's legislative districts were unconstitutional. Specifically, the court noted that the population figures the state had used for its districts substantially deviated from US Census figures because the state had used the total vote cast in a district as part of its formula for calculating population. This led to districts that varied by up to 94% from the population ideal for house districts, and 83% for senate districts. The court held that states can only take into account the voting rates of a district if the end result is not significantly different from population numbers. Further, states can only use non-population criteria if they have a rational basis and do not eliminate substantial equality. Because the use of voting rates led to substantial deviations from equal representation, the court ordered the New Mexico legislature to reapportion the districts in accordance with actual population figures. 550 F. Supp. 13.
Under 28 USC § 1253, a case heard by a three-judge panel is generally directly appealable to the Supreme Court. The defendants appealed this case, but the Supreme Court affirmed the panel's decision (without issuing a written opinion) on October 4, 1982. 103 S.Ct. 32. This case is now closed.
Summary Authors
Kyle O'Hara (2/21/2025)
State / Territory:
Case Type(s):
Key Dates
Filing Date: 1982
Closing Date: Oct. 4, 1982
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Individuals and the United States
Plaintiff Type(s):
U.S. Dept of Justice plaintiff
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Defendant Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Other Dockets:
District of New Mexico 82-cv-00067
District of New Mexico 82-cv-00084
District of New Mexico 82-cv-00180
District of New Mexico 82-cv-00219
Available Documents:
Outcome
Prevailing Party: Plaintiff
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Content of Injunction:
Issues
Voting: