Background
In 2025, the Missouri legislature enacted House Bill 1, repealing the state’s 2022 congressional district map and replacing it with a new eight-district map (“2025 Map”). Two separate groups of Missouri residents filed suit in Jackson County circuit court, each alleging the 2025 Map violated article III, section 45 of the Missouri Constitution, which requires congressional districts to be comprised of “contiguous territory as compact and as nearly equal in population as may be.” The Wise Appellants challenged the map’s overall compactness, its alleged equal-population violation arising from splitting voting tabulation district KC 811 between two congressional districts, and a related contiguity claim. The Healey Appellants focused their challenge on congressional districts 4, 5, and 6, arguing that dividing the Kansas City metropolitan area among those three districts violated the compactness requirement.
The circuit court consolidated the cases and conducted a four-day bench trial in February 2026. Both sides presented expert witnesses who applied multiple statistical compactness measures — including the Reock, Polsby-Popper, Convex Hull, and Schwartzberg indices, as well as the qualitative IKIWISI measure — to compare the 2025 Map against the 2022 and 2012 maps. Kansas City Mayor Quinton Lucas testified that the 2025 Map divided “communities of interest,” and Appellants introduced alternative district maps. The circuit court entered judgment for the State, finding Appellants had not carried their burden of establishing that the 2025 Map clearly and undoubtedly violated the constitution’s compactness, contiguity, or equal-population requirements. Both groups of residents appealed directly to the Missouri Supreme Court, which has jurisdiction over challenges to the constitutional validity of a state statute.
A separate question — whether the mere filing of referendum petitions automatically suspended HB 1 — was resolved in a companion case, Maggard v. State, No. SC101581 (Mo. banc May 12, 2026). An earlier question about whether the legislature had authority to redraw the map mid-decade was resolved in Luther v. Hoskins, 730 S.W.3d 567 (Mo. banc 2026), and Appellants voluntarily dismissed that claim below. Neither the Wise nor Healey Appellants raised a partisan gerrymandering challenge, which the U.S. Supreme Court has held is generally beyond judicial review. See Rucho v. Common Cause, 588 U.S. 684 (2019).
The Court’s Holding
The Missouri Supreme Court affirmed the circuit court’s judgment in full. Applying the high burden required of redistricting challengers — the map is presumed constitutional and will not be struck down unless it “clearly and undoubtedly” contravenes the constitution and “plainly and palpably affronts fundamental law” — the Court held that Appellants failed to establish the 2025 Map violated article III, section 45. The Court reviewed legal questions de novo and deferred to the circuit court’s factual findings, including credibility determinations, so long as supported by competent, substantial evidence.
On compactness, the Court rejected Appellants’ argument that the circuit court improperly relied exclusively on statistical measures. The record showed the circuit court applied a totality-of-the-evidence analysis, weighing statistical scores alongside historical maps, population density, and county and municipal splits — exactly the multifactor inquiry required by Pearson II. The Court also rejected the argument that the circuit court failed to conduct a district-by-district analysis; the circuit court had explicitly evaluated districts 4, 5, and 6, finding each more compact than the corresponding districts in the 2012 Map that this Court upheld in Pearson II. Across every major compactness metric — Polsby-Popper, Reock, Convex Hull, Schwartzberg, and IKIWISI — the 2025 Map outperformed both the 2022 and 2012 maps statewide, and the 2025 Map’s Convex Hull average of 0.802 was the best recorded for Missouri since at least 1972.
The Court reaffirmed that drawing congressional districts is a predominantly political process best left to elected representatives, and that courts are limited to determining legality — not prudence or popularity. Because the 2025 Map’s districts constitute “contiguous territory as compact and as nearly equal in population as may be” under article III, section 45, the political judgments embedded in the map are entitled to judicial respect.
Key Takeaways
- A challenger to a Missouri congressional redistricting map bears the heavy burden of proving the map “clearly and undoubtedly” violates the state constitution; doubts are resolved in favor of constitutionality.
- Compactness under article III, section 45 means “closely united territory” and is not determined by physical shape alone; courts must look at the totality of the evidence, including statistical measures, historical maps, population density, and county and municipal splits.
- Statistical compactness scores are a relevant factor but not independently dispositive; a circuit court may rely on them as part of a broader, multifactor analysis without committing reversible error.
- Each district must be examined individually for compactness, but because district boundaries are interdependent, the map as a whole remains a relevant — if secondary — consideration.
- Partisan gerrymandering, though potentially at issue given the mid-decade redraw, is generally not subject to judicial review under federal precedent, and neither group of challengers raised such a claim.
Why It Matters
This decision clarifies the evidentiary framework Missouri courts must apply when evaluating congressional redistricting challenges, reinforcing that statistical compactness measures are useful tools — not the whole test — and that challengers face a demanding burden before courts will override legislative line-drawing. The ruling also confirms that mid-decade redistricting, when otherwise lawful, is not inherently infirm under the Missouri Constitution.
For practitioners and redistricting advocates, the case highlights the practical importance of building a comprehensive trial record — including expert testimony on multiple compactness metrics and comparisons to historically upheld maps — and signals that communities-of-interest arguments and post-hoc alternative maps carry limited weight absent a showing that the enacted map crosses a constitutional line. With Missouri’s referendum process for HB 1 still unresolved in the companion Maggard litigation, the ultimate fate of the 2025 Map at the ballot box remains an open question.