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National Association for the Advancement of Colored People v. Merrill

The NAACP and various members filed suit to challenge Connecticut’s 2011 state legislative maps, contending that the maps violate the Fourteenth Amendment because of prison gerrymandering.

Last Updated: April 20, 2020
Published: September 24, 2019

Note: The Brennan Center is not a participant in this case.

Case Background

The NAACP, along with the NAACP Connecticut State Conference and five Connecticut NAACP members, filed a lawsuit in federal district court contending that Connecticut’s 2011 state legislative maps violate the “one person, one vote” principle of the Fourteenth Amendment because of unlawful prison gerrymandering. The plaintiffs define prison gerrymandering as the practice of counting prisoners as residents of the district in which they are imprisoned rather than at their home addresses for the purpose of drawing state legislative districts. The plaintiffs argue that this practice dilutes the voting power of the predominantly African American and Latino prisoners’ home communities.

The plaintiffs have asked the court to enjoin the 2011 maps. In the event the legislature does not pass a constitutional redistricting plan, the plaintiffs request the court order a new set of maps to be drawn.

On February 15, 2019, the court denied the defendants’ motion to dismiss, ruling, among other things, that the Eleventh Amendment did not bar the plaintiffs’ suit. On March 7, 2019, the defendants appealed the decision and requested a stay pending that appeal. On July 15, 2019, the Second Circuit Court of Appeals granted the stay and ordered an expedited appeal. Oral argument took place at the Second Circuit on September 10.

On September 24, the Court of Appeals affirmed the district court’s Eleventh Amendment ruling and remanded the case with instructions to the district court to refer future proceedings to a three-judge panel.

The three-judge panel set a briefing schedule for the remaining proceedings, with oral argument on any dispositive motions set for June 16, 2020.

On April 14, 2020, the parties filed a joint stipulation for dismissal, which the court granted on April 16. 


District Court

Second Circuit Court of Appeals