Missouri Supreme Court upholds 2025 congressional redistricting map

Summary

• The Missouri Supreme Court affirmed a lower court ruling upholding the state’s 2025 congressional map.
• Challengers argued the map violated constitutional compactness, contiguity and equal population requirements.
• The court said the challengers failed to show the map violated article III, section 45 of the Missouri Constitution.
• A separate May 12 ruling held referendum petitions did not automatically suspend House Bill 1.

The Missouri Supreme Court on May 12 affirmed a lower court’s judgment upholding the state’s redrawn congressional map, leaving Missouri’s eight districts in place ahead of the 2026 election cycle.

In a unanimous opinion authored by Chief Justice W. Brent Powell, the court held that challengers in two consolidated cases failed to show the 2025 congressional map violates Article III, Section 45 of the Missouri Constitution, which requires congressional districts to be composed of contiguous territory “as compact and as nearly equal in population as may be.”

Powell framed the court’s review narrowly, saying it was “limited to determining only the legality — not the prudence or popularity — of the map.”

The opinion came in the consolidated cases Elizabeth Healey, et al. v. State of Missouri, et al. and Terrence Wise, et al. v. State of Missouri, et al.

The legislature had originally drawn Missouri’s eight congressional districts in 2022, following the 2020 decennial census. During a special session in September 2025, lawmakers passed House Bill 1, which repealed the 2022 map and created a new congressional district map.

In Healey, a group of 16 individuals sued the state, the secretary of state, and the Jackson County and Kansas City boards of election commissioners, along with their respective commissioners and directors. They alleged that Districts 4, 5 and 6 of the 2025 map violate the compactness requirement of Article III, Section 45.

The Wise case was brought by four individuals who lived in District 5 under the 2022 map and raised additional constitutional claims beyond compactness, including whether the 2025 map satisfies equal population and contiguity requirements. The Wise challengers argued that a voting tabulation district, KC 811, was assigned to both District 4 and District 5.

The Missouri Republican State Committee was allowed to intervene in both cases. The circuit court consolidated the cases and conducted a four-day bench trial beginning Feb. 17. After trial, the circuit court entered judgment in favor of the respondents, finding the challengers had not carried their burden of establishing the 2025 map violated the compactness, contiguity or equal population requirements of Article III, Section 45.

The Healey and Wise appellants also initially alleged the legislature lacked authority to enact the 2025 map after the 2022 map was enacted. The Supreme Court resolved those claims in a separate case, Luther v. Hoskins, and the appellants dismissed those claims. The opinion also noted that neither group challenged the 2025 map on partisan-gerrymandering grounds.

“Gerrymandering involves the political manipulation of electoral district boundaries to advantage a political party or other group,” the opinion stated. “While discouraged, gerrymandering for purely partisan purposes is not ordinarily subject to judicial review, according to the United States Supreme Court, and may explain why Appellants did not raise such a claim.”

A separate May 12 opinion addressed whether referendum petitions seeking to repeal HB 1 suspended the 2025 map before the secretary of state completed the signature certification process. In Maggard v. State, the court held that the mere submission of referendum petitions did not automatically suspend HB 1. The Healey and Wise opinion, however, focused only on the constitutional validity of the map as drawn under Article III, Section 45.

The challengers in Healey and Wise appealed the circuit court’s judgment, bringing the issue before the state’s highest court. Oral arguments were heard May 12, the same day the court issued its opinion. Asseem Mulji of Campaign Legal Center in Washington, D.C., argued for the challengers in Healey. Abha Khanna of Elias Law Group in Seattle argued for the challengers in Wise. Kathleen T. Hunker of the attorney general’s office in Jefferson City argued for the state in Healey, while John M. Gore of Jones Day in Washington, D.C., argued for the Missouri Republican State Committee in Wise.

On the compactness arguments, the court rejected the challengers’ claim that the circuit court had relied too much on statistical measures. The opinion stated that while such measures may be used in a compactness analysis, they “alone do not demonstrate that a map is or is not compact.”

“Appellants argue a circuit court cannot rely on statistical measures alone when determining a challenged district’s compactness and, instead, must look to the totality of the evidence,” Powell wrote. “This is correct — alone, statistical measures of compactness do not demonstrate a map is compact; however, they can be used as a factor in the court’s analysis of a district’s compactness. In fact, Appellants introduced and relied on statistical metrics in arguing certain districts were not compact.”

The district-by-district challenge fared no better. Powell wrote that the circuit court “explicitly considered the three challenged districts” when analyzing the 2025 map and noted that looking at the map as a whole was also appropriate because “the compactness of one district necessarily affects the compactness of another district.”

Comparing the 2025 map to its predecessors was likewise fair game, the court held. Powell wrote that historical boundary lines are legally relevant in determining compactness, and that comparing the 2025 map to the 2022 map was particularly appropriate given the challengers were asking the court to revert to that earlier map.

The communities-of-interest arguments drew a similar conclusion. The court declined to decide whether such evidence could bear on compactness at all, finding the question moot because the circuit court had considered it anyway and still found the challengers fell short of their burden.

The court also found the circuit court did not err in its treatment of alternative map evidence. The court wrote that alternative maps are relevant evidence in compactness litigation, but the circuit court did not exclude or fail to consider the challengers’ alternative maps. Instead, it gave the evidence less weight than the challengers wanted.

“Appellants had to prove the 2025 Map and the challenged districts fail the compactness requirements, not that there is a better way to meet the requirements,” Powell wrote. “They failed to do so.”

The court also rejected the Wise challengers’ equal population and contiguity claims involving KC 811. The circuit court found the Wise appellants presented no evidence at trial to support those claims.

Summarizing the circuit court’s findings, Powell wrote that “a single VTD KC 811 is not assigned to two districts.” Rather, the circuit court found “there are two separate VTDs referred to as KC 811,” allowing one to be assigned to District 4 and the other to District 5.

The court found the circuit court did not misapply the law in interpreting HB 1 that way. Powell wrote that the plain and ordinary meaning of HB 1 provided that one VTD KC 811 is assigned to District 4, while the other is assigned to District 5.

The court affirmed the circuit court’s judgment and said no Rule 84.17 motions are permitted.

The cases are Elizabeth Healey, et al. v. State of Missouri, et al. and Terrence Wise, et al. v. State of Missouri, et al., Case Nos. SC101570 and SC1015732.