LaBrant et al v Benson - Case Brief

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Modified: 12th Jan 2024
Wordcount: 355 words
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LaBrant et al v. Benson, No. 1:2019cv00306 - Document 43

Supreme Court No. 166470
Court of Appeals No. 368628
Lower Court No. 23-000137-MZ

Facts

In 2018, the People of the State of Michigan passed Proposal 2, a constitutional amendment that created an independent citizen redistricting commission for state legislative and congressional districts (Michigan, 2018). The amendment conferred the Secretary of State with the supervisory role over the commission. Soon after, LaBrant et al. sued Secretary of State, Jocelyn Benson, alleging that the selection process for the commission violated their constitutional rights, more particularly the right to equal protection and political association (LaBrant et al v. Benson, 2019).

Issue

The primary issue at hand was whether the exclusion of certain individuals and their relatives from being eligible for serving on the independent citizen redistricting commission was violative of their constitutional rights.

Holding and Rule

The court held in favor of Benson, stating that Proposal 2 did not violate the plaintiffs' constitutional rights. The court reasoned that the exclusion criteria simply aimed at limiting conflicts of interest and ensuring the impartiality of the redistricting process, which were legitimate governmental interests. Furthermore, the court found no substantial burden on the plaintiffs' rights to political association, as they were still free to influence the redistricting process in various ways outside of the commission (LaBrant et al v. Benson, 2019).

Disposition

The court dismissed the case, upholding the constitutionality of the commission and its selection process outlined under Proposal 2.

References

LaBrant et al v. Benson, No. 1:2019cv00306 - Document 43 (W.D. Mich. 2020).

Michigan, Secretary of State. (2018). 2018 Michigan Election Law Proposal 2, INITIATIVE PETITION AMENDMENT TO THE CONSTITUTION.

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