Term: 2015
Docket: 14-990
Shapiro v. Mcmanus
- Pro
14-990 SHAPIRO V. McMANUS DECISION BELOW: 584 Fed.Appx. 140 CERT. GRANTED 6/8/2015 QUESTION PRESENTED: The Three-Judge Court Act requires the conven-ing of three-judge district courts to hear a wide range of particularly important lawsuits, including constitutional challenges to the apportionment of congressional districts and certain actions under the Voting Rights Act, Bipartisan Campaign Reform Act, Prison Litigation Reform Act, and Communications Act. The Three-Judge Court Act provides that a three-judge court shall be convened to hear such cases unless the single judge to whom the case is initially referred "determines that three judges are not required." 28 U.S.C. § 2284(a), (b)(1). In Goosby v. Osser, 409 U.S. 512 (1973), this Court held that the Three-Judge Court Act "does not require the convening of a three-judge court when the [claim] is insubstantial." Id. at 518. A claim is insubstantial "for this purpose" if it is "'obviously frivolous,''' "'essentially fictitious,'" or "inescapably * * * foreclose[d]" by this Court's precedents. Ibid. The question presented, which has divided the lower courts, is as follows: May a single-judge district court determine that a complaint covered by 28 U.S.C. § 2284 is insubstantial, and that three judges therefore are not required, not because it concludes that the complaint is wholly frivolous, but because it concludes that the complaint fails to state a claim under Rule 12(b)(6)? LOWER COURT CASE NUMBER: 14-1417
The Shapiro v. McManus case in 2015 revolved around the issue of whether a single district judge, rather than a three-judge panel, could dismiss a claim alleging unconstitutional gerrymandering. The plaintiffs were Maryland residents who claimed that their First Amendment rights had been violated by redistricting measures designed to dilute their voting power for partisan reasons. Initially, the District Court dismissed the case without referring it to a three-judge court as required under federal law for certain types of constitutional challenges against apportionment legislation. However, upon appeal at Supreme Court level, it was unanimously decided that this dismissal was incorrect and should have been heard by such a panel according to statute 28 U.S.C §2284(a). Therefore, the Supreme Court reversed and remanded the decision back down to be heard before an appropriately constituted court.
In the case of Shapiro v. McManus, there was no dissenting opinion as the decision by the Supreme Court was unanimous. The court ruled 9-0 in favor of Shapiro and his co-petitioners, stating that a single-judge district court's dismissal of their claim as "constitutionally insubstantial" did not bar them from seeking a three-judge panel to hear their case. This ruling emphasized that any claim invoking Section 2a(c) should be heard by a three-judge panel unless it is wholly frivolous or essentially fictitious.
