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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