Case: Healey v. Missouri

This case challenges Missouri's 2025 congressional plan, based on an alleged state constitutional prohibition on mid-decade redrawing and state provisions on compactness.

On September 28, 2025, a group of Missouri voters filed a state lawsuit in the Circuit Court of Jackson County, Missouri against the State of Missouri, the Secretary of State, the Jackson County Board of Election Commissioners, and the Kansas City Board of Election Commissioners, challenging the state’s newly enacted 2025 congressional redistricting plan. Represented by private counsel, the plaintiffs alleged that the 2025 congressional plan violated the state constitution’s prohibition on mid-decade redrawing of congressional maps and state provisions on compactness. The plaintiffs sought a declaratory judgment, a permanent injunction to prevent Missouri from holding elections under the 2025 maps, and attorneys’ fees.    

The voters alleged that House Bill 1 (“HB 1”), the mid-cycle redistricting bill, was introduced in September 2025 after President Trump placed pressure on Republican-led states to redraw their congressional maps to boost the party’s chances in the 2026 midterm elections. The newly drawn 2025 congressional maps would result in a 7-1 Republican-controlled map, shifting one congressional seat to Republicans. The plaintiffs argued that redrawing congressional maps mid-cycle violated Article III, Section 45 of the Missouri Constitution, which mandates the General Assembly to redraw congressional maps following receipt of census results each decade, as has been Missouri’s usual redistricting process for at least a century. The plaintiffs further alleged that the 2025 redrawn congressional maps violated the compactness requirement of the Missouri Constitution, which requires each congressional district to be drawn as “compact . . . as may be” so that communities sharing similar interests and facing similar challenges are kept together.  One significant change made in the 2025 congressional maps was to split former Congressional District 5, the district that contained much of Kansas City, among three different districts. Under the 2025 redrawn maps, Kansas City voters were grouped with rural voters, some of whom were located hundreds of miles away, and as a result, Kansas City voters would no longer have a unified voice with respect to issues most important to urban voters.

On October 3, 2025, the plaintiffs filed a motion seeking to join their mid-decade redistricting claim with Wise v. Missouri because the Wise case was first filed in Jackson County and both cases arose out of the same transaction and involved common questions of law and fact.

On October 17, 2025, the defendants filed a motion to dismiss, or, in the alternative, to transfer the case to Cole County, Missouri. The defendants argued that Cole County had exclusive jurisdiction over redistricting cases and that the plaintiffs’ claims duplicated a previously filed suit in Cole County that also named the Secretary of State as a defendant, Luther v. Hoskins, 25AC-CC06964 (Cir. Ct. Cole Cnty).

On November 17, 2025, the Missouri Republican State Committee moved to intervene as a defendant, alleging they had a substantial interest in HB 1 since the bill established the boundaries of Missouri’s congressional districts in which Republican candidates will seek election and therefore Republican candidates supported by the committee would be affected directly by the outcome of the litigation.

A hearing on the motions was held on November 24, 2025. On December 10, 2025, the court granted the plaintiffs’ motion to consolidate this case with Wise v. Missouri, granted the motion to permit the Missouri Republican State Committee to intervene as a defendant, and denied the defendants' motion to dismiss. The court stayed proceedings on Count I (constitutionality of mid-decade redistricting) pending resolution of a similar, if not identical, claim being litigated in Luther v. Hoskins, which was on appeal to the Missouri Supreme Court.

A bench trial was held on Count II (violation of the state constitution's compactness requirement) and other counts from Wise v. Missouri from February 17–20, 2026.  At trial, the plaintiffs’ experts presented testimony that the legislature could have redrawn the districts by keeping more of Kansas City together. The defendants’ experts presented statistical measures commonly used to evaluate district compactness and demonstrated that the 2025 maps were generally consistent with prior Missouri congressional maps in terms of compactness, and in some cases, the 2025 redrawn maps performed better than prior maps under certain tests.

On March 12, 2026, the court ruled on Count II and held that the plaintiffs failed to prove that the 2025 redrawn congressional maps violated the state’s compactness requirement. The court, therefore, declined to strike down the 2025 maps. Given the high legal standard required to overturn a legislative redistricting plan, the court concluded that the plaintiffs did not “clearly and undoubtedly” prove that HB 1 violated the state constitution’s compactness requirement. The court emphasized that Missouri law does not require the legislature to maximize compactness above all other factors, noting that redistricting is an inherently political process and the legislature may weigh compactness along with other factors such as keeping counties and municipalities intact, maintaining contiguous districts, and ensuring equal population among districts. The court allowed the 2025 redrawn maps to remain in place while the broader question of the constitutionality of mid-decade redistricting authority continued to be considered by the Missouri Supreme Court.

On March 16, 2026, the plaintiffs filed a voluntary dismissal without prejudice of Count I (constitutionality of mid-decade redistricting) against all defendants, as no evidence regarding Count I had been introduced given that all proceedings on that count were stayed after pre-trial motions.  The plaintiffs requested that the court enter final judgment on all counts.

As of March 18, 2026, this case is ongoing, with the Missouri Supreme Court to hear arguments in May 2026.