Lance v. Coffman

PETITIONER: Keith Lance et al.
RESPONDENT: Mike Coffman, Colorado Secretary of State
LOCATION: United States District Court for the District of Colorado

DOCKET NO.: 06-641
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Federal district court

CITATION: 549 US 434 (2007)
DECIDED: Mar 05, 2007
GRANTED: Nov 06, 2006

Facts of the case

After the 2000 census, the U.S. Congress increased Colorado’s representation in the U.S. House of Representatives from six congressmen to seven. The Colorado state legislature failed to redraw the districts before the 2002 elections, so the state courts redrew the districts. In 2003, the Colorado state legislature redrew a different district map, which resulted in Colorado having two conflicting district maps. The Colorado Supreme Court ruled that the Colorado state constitution only allows district maps to be redrawn once per census, and therefore the courts’ 2002 redistricting took precedence over the redistricting by the state legislature.

Keith Lance and three other Colorado citizens sued in federal district court and argued that the Colorado Supreme Court’s decision violated the Election Clause of Article I of the U.S. Constitution, and those individuals’ First and Fourteenth Amendment rights to file for redress of grievances. The district court held that they did not have jurisdiction and dismissed the case. Lance appealed to the U.S. Supreme Court, which held that the district court did have jurisdiction to hear the case. The Supreme Court remanded the case back to the district court of Colorado, which dismissed the case on the grounds of issue preclusion, since Lance was an individual citizen not directly affected by the redistricting ruling. Lance again appealed to the U.S. Supreme Court.

Question

Does an individual citizen have standing in a personal suit for violation of the Elections Clause of Article I of the U.S. Constitution?