Lance v. Coffman, 549 U.S. 437 (2007)

In the case of Lance v. Coffman, the underlying dispute arose from Colorado's congressional redistricting process following the 2000 census. Initially, when the Colorado legislature failed to redraw the congressional districts, a state court intervened and created a new districting plan. Subsequently, in 2003, the legislature passed its own redistricting plan, which was signed into law by the Governor. However, the Colorado Attorney General filed an action in the Colorado Supreme Court to prevent the implementation of this new plan, citing a provision in the Colorado Constitution that limits redistricting to once per census. The Colorado Supreme Court ruled in favor of the Attorney General, stating that the judicially-created districts were as binding as those created by the legislature and that the court-drawn plan would remain in effect until the next census. Following the Colorado Supreme Court's decision, four Colorado citizens, who had not participated in the earlier case, filed a lawsuit in Federal District Court. They contended that the Colorado Supreme Court's interpretation of the state constitution violated their rights under the Elections Clause of the U.S. Constitution. The District Court initially determined it lacked jurisdiction based on the Rooker-Feldman doctrine but was later instructed by the Supreme Court to reconsider the case. On remand, the District Court acknowledged that the plaintiffs had standing to challenge the Elections Clause but ultimately ruled that their suit was barred by issue preclusion, as they were considered to be in privity with the Secretary of State and the General Assembly, who had lost in the earlier state court litigation. The case reached the Supreme Court of the United States on appeal after the District Court's ruling. The procedural history reflects a complex interplay between state and federal courts regarding the authority to regulate elections and the interpretation of state constitutional provisions. The plaintiffs' challenge raised significant questions about the jurisdiction of federal courts in cases involving state constitutional law and the implications of the Elections Clause in the context of state-drawn electoral districts.

Whether the plaintiffs have standing to challenge the constitutionality of the Colorado Supreme Court's interpretation of Article V, §44 of the Colorado Constitution under the Elections Clause of the United States Constitution.

The judgment of the United States District Court for the District of Colorado is therefore vacated in part, and the case is remanded with instructions to dismiss the Elections Clause claim for lack of standing. We affirm the District Court’s dismissal of the Petition Clause claim.