The Supreme Court of Missouri on March 24 upheld the constitutionality of Missouri’s mid-decade congressional redistricting law, affirming a lower court ruling that House Bill 1 does not violate the state constitution.
In Luther v. Hoskins, a majority of the Court, 4-3, found that Article III, Section 45 of the Missouri Constitution does not prohibit the General Assembly from redrawing congressional districts outside the decennial census cycle. The decision allows the state’s 2025 redistricting plan to remain in place.
The case centered on whether the Constitution limits lawmakers to a single round of redistricting following each federal census. Plaintiffs argued that the constitutional language requiring redistricting “when” census results are certified to the governor implicitly restricts the legislature from acting at other times.
The Court rejected that argument, holding that the provision creates an obligation to redraw districts after each census but does not bar additional redistricting. The majority emphasized that the Missouri Constitution functions primarily as a limitation on legislative power, and because it does not expressly prohibit mid-decade redistricting, the legislature retains that authority.
“The obligation to legislate congressional districts once a decade does not limit the General Assembly’s power to redistrict more frequently,” the Court wrote, concluding that House Bill 1 does not “clearly contravene” the Constitution.
The ruling affirms a Cole County circuit court decision that found the law to be a valid exercise of the legislature’s authority. The redistricting measure repealed congressional maps adopted in 2022 and replaced them with new district boundaries in 2025, without a new census.
The decision was not unanimous. In a dissenting opinion, several judges argued that Article III, Section 45 does impose a limit on when redistricting can occur. The dissent contended that by specifying the timing of redistricting following the census, the Constitution implies that lawmakers are not authorized to redraw districts at other times.
The dissent also pointed to the historical context of the provision and the structure of the Constitution, arguing that it was intended to ensure redistricting occurs at regular intervals tied to population data, rather than at the discretion of the legislature.
The majority disagreed, stating that any limitation on legislative power must be clearly expressed in the Constitution or arise by necessary implication. It found no such restriction in the text of Article III, Section 45.
With the ruling, Missouri joins states where courts have allowed mid-decade congressional redistricting. The decision confirms that the General Assembly may redraw congressional districts more than once per decade, provided no other constitutional provisions are violated.
The case establishes a precedent for how Missouri courts will interpret legislative authority over redistricting, reinforcing a broad view of the General Assembly’s power absent explicit constitutional limits.
