Is Mid-Decade Redistricting the New Normal? (Court Report)

Mid-decade redistricting used to be more rare. Recent developments, however, indicate that it may not be a temporary diversion from the standard practice, but rather a new normal that will continue to appear every election season.

Over a year has passed since President Donald Trump urged Texas to redraw its congressional district maps mid-decade to increase Republican power in Congress. Before 2025, only two states had performed voluntary mid-decade redistricting since 1970. President Trump's call to action, however, prompted at least ten additional states to attempt their own mid-decade changes, resulting in political upheaval and a litany of judicial challenges. With the election about six weeks away, it is worth taking a look at where the dust has settled in redistricting debates and whether or not they will likely continue on into the future.

Which States Successfully Enacted New Congressional Maps

Voluntary Mid-Decade Redistricting States

As a result of President Trump's call to action, five states (California, Florida, North Carolina, Tennessee, and Texas) were able to voluntarily enact new congressional district maps and successfully defend them against court challenges. California's redistricting is expected to yield five additional Democratic seats in the House of Representatives, while Florida and Texas could produce a four-seat and five-seat gain for Republicans, respectively. North Carolina and Tennessee could each add one Republican seat.

Court-Ordered and Legally Required Redistricting

In addition to the voluntary mid-decade redistricting, earlier lawsuits and legal requirements led to new maps in four other states. The Supreme Court's April decision in Louisiana v. Callais, which struck down Louisiana's second majority-Black district and narrowed when the Voting Rights Act requires states to consider race, allowed for the implementation of maps in Alabama and Louisiana, which had been challenged prior to 2025. These five maps could give Republicans one additional seat in each state. Ohio also adopted a new map, as required by a 2018 constitutional amendment that limits some maps to four years. The new map favors Republicans in 12 of the state's 15 districts. Finally, in February, the Utah Supreme Court and a federal court both declined to block the state's court-ordered map, affording a possible additional seat to Democrats. Altogether, the new maps could give Republicans a net gain of as many as nine seats.

Missouri Redistricting Legal Battles

Missouri is an instructive example of how messy redistricting can be. In September 2025, Missouri Governor Mike Kehoe (R) approved a new congressional district map passed by the legislature that was expected to net an additional seat for Republicans in the U.S. House of Representatives. Opponents quickly submitted a veto referendum to repeal the new congressional maps, and in early September, the Missouri Supreme Court ruled the referendum was valid, ordered it onto the November ballot, and blocked the new map in the meantime.

Proponents then appealed to the U.S. Supreme Court who ultimately rejected the emergency request, leaving the original ruling in place. Shortly thereafter, in a separate case, a federal judge in Missouri ruled that the Constitution requires that the new map be used in the November election because it was used in the August primaries. Missouri Secretary of State Denny Hoskins (R) immediately provided guidance that the 2025 map should be used, prompting the state Supreme Court to find him guilty of contempt for failing to comply with the original injunction. The U.S. Supreme Court was then forced to weigh in again, requiring election officials to use the old congressional district map while the federal case is being litigated. Despite being seemingly resolved, the Eighth U.S. Circuit Court of Appeals ruled on September 21 that the state must use the new map, previously rejected by the Supreme Court. The ruling came just one day before absentee and mail-in ballots were set to be sent out, but has been paused to allow for the Supreme Court to weigh in yet again.

Maryland Prepares for Future Redistricting

Those hoping the election will end the redistricting fight may be disappointed, based on recent events in Maryland. On August 5, Maryland Governor Wes Moore (D) signed MD HB 2100 into law to place a constitutional amendment on the November ballot that, if ratified by voters, would clarify that the districting standards contained within the state Constitution only apply to elections of members of the state General Assembly and not congressional districts. It would also let lawmakers send challenges to congressional maps straight to the Maryland Supreme Court. The bill was passed by the legislature during an emergency special session on congressional redistricting and was backed by Democrats to lay the groundwork to alter congressional districts for the 2028 elections. Governor Moore had resisted calls for redistricting for months, advocating instead for national reform, but later called for the special session, stating, "I continue to believe that our country needs national redistricting reform. But until that happens, inaction is not an option." Less than a month after signing, however, a Maryland court ruled that the ballot measure could not appear on the ballot as it not only did not make the July 1 deadline for the Secretary of State to certify statewide ballot questions, but also included "intentionally misleading" language. The judge did pause the effect of the ruling to allow for an appeal to the Supreme Court.

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