League of Women’s Voters of Chicago v. City of Chicago

Dist. Ct. did not err in granting defendant’s motion to dismiss for failure to state cause of action in plaintiff’s lawsuit alleging that defendant’s 2015 aldermanic remap violated equal protection clause. Maximum deviation of 8.7 percent in population between wards was too small to establish prima facie case of unconstitutionality, and plaintiff’s claim that new map was targeted against independent Democratic aldermen did not serve to rebut presumption of constitutionality for maps with deviations less than ten percent. Ct. further rejected plaintiff’s claim that: (1) new map departed from traditional redistricting standards, since such contention was not valid basis for equal protection violation; and (2) defendant had improperly implemented new map prematurely, where record failed to show existence of city policy demonstrating that it was currently using 2015 map.