Benisekv.Lamone
Republican Maryland voters alleged that the State’s 2011 congressional map was drawn to retaliate against them because of their political views. Six years after the map was adopted and after three elections had occurred, they sought a preliminary injunction preventing officials from using it in the 2018 election. The district court denied relief and stayed the case while the Supreme Court considered a related partisan-gerrymandering case. The Supreme Court affirmed. A preliminary injunction is an extraordinary remedy, and even an assumed likelihood of success does not eliminate the requirements of likely irreparable harm, favorable equities, and the public interest. The voters’ delay in presenting the retaliation theory undermined their request for emergency relief, while the approaching election deadline and unresolved legal standards made an injunction disruptive. The Court held that the district court acted within its equitable discretion in denying the injunction and waiting for further guidance. The decision did not resolve whether Maryland’s map violated the Constitution.
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