Benisek v. Lamone

Benisek v. Lamone was a U.S. Supreme Court case decided on June 18, 2018, concerning partisan gerrymandering of Maryland's 6th Congressional District. Republican voters, led by O. John Benisek, sued state election administrator Linda H. Lamone, alleging that the Democrat-controlled state government deliberately redrew district boundaries in 2011 to dilute their votes, violating the First Amendment's speech and association rights. The plaintiffs sought a preliminary injunction to bar use of the map for the 2018 election. The district court denied the injunction, and the Supreme Court affirmed in a per curiam decision, holding that the plaintiffs failed to demonstrate irreparable harm given the timing and the advanced stage of the litigation. The case was remanded for further proceedings on the merits without deciding the constitutionality of partisan gerrymandering.

The Supreme Court affirmed the district court's denial of a preliminary injunction, allowing the challenged district map to remain in place for the 2018 election and remanding the case for further litigation on the underlying constitutional claims.

Whether the 2011 redrawing of Maryland's 6th Congressional District constituted unconstitutional partisan gerrymandering in violation of the First Amendment, and whether the plaintiffs demonstrated irreparable harm to warrant a preliminary injunction halting use of the map in the 2018 election.

The ruling preserved the status quo for the 2018 midterm elections, intensifying the national debate over partisan gerrymandering. It demonstrated the judiciary's reluctance to intervene in redistricting disputes without clear, manageable standards. This hesitation foreshadowed the 2019 decision in Rucho v. Common Cause, where the Court ultimately held that partisan gerrymandering claims present political questions beyond the reach of federal courts, fundamentally shaping the legal landscape for election law.