This is the second case in as many years dealing with an electoral district map from Arizona drawn by a commission of two Republicans, two Democrats, and a Neutral individual. The first case, from last year, determined that such a commission was legal. Harris addresses whether the map itself was drawn within the bounds of Constitutional limits and without being based on impermissible reasonings. In a rather straight forward analysis the arguments against the district map were found to be insufficient. In other words, the map was upheld.
There was an interesting argument, there was a claim the map represented gerrymandering on the basis of party affiliation. Specifically, in drawing the map the Commission had the inappropriate purpose of securing political advantage for one party. The important part of this discussion was the test articulated: in challenging an electoral district map for improper political considerations is that “it is more probable than not that illegitimate considerations were the predominant motivation behind the plan’s deviations from mathematically equal district populations.”
This test in essence demands only the proof that an electoral map was drafted with political considerations in mind. Records from the discussion around the electoral map and other related documents need to show a tendency that the reasoning behind the actions was political gain. Admittedly, this will be difficult to demonstrate. After all, it is not as common anymore for people, politicians especially, to declare on the record an impermissible purpose.
Furthermore, these cases are less likely to be brought in the coming years for a simple reason. If there were alleged hijinks in the creation of an electoral map, the time to bring the case is around the time the map is drawn. Typically, though not always, electoral maps are drawn around the U.S. Census. The last Census was taking in 2010, meaning the next Census will be in 2020. Most maps are scheduled to be redrawn based on those results. Thus, it is likely the next set of electoral map challenges will be after 2020.
Harris may be less impactful then some other SCOTUS cases, however, the language around what is impermissible political gerrymandering may still have significant impact. Like many cases, the impact of Harris will not be known for years to come.