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Utah Supreme Court denies Legislature’s bid to stay injunction against 2021 congressional map

September 15, 2025 | Utah Appellate Court, Utah Judicial Branch, Utah


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Utah Supreme Court denies Legislature’s bid to stay injunction against 2021 congressional map
The Utah Supreme Court, in a per curiam opinion filed Sept. 15, 2025, denied the Utah State Legislature’s emergency petition seeking a stay of a Third District Court injunction that prohibits use of the 2021 congressional map (H.B. 2004). The Legislature had asked the high court to suspend the district court’s injunction while the parties complete a court-ordered remedial process and pursue appeals.

The issue before the Supreme Court was narrow: whether the district court abused its discretion by refusing to stay its permanent injunction against the 2021 map. The Supreme Court concluded the Legislature had not shown such an abuse of discretion and therefore was not entitled to extraordinary relief under Utah Rule of Appellate Procedure 19(a) and Utah Rule of Civil Procedure 65B(d).

The background to the dispute dates to 2018, when voters passed the citizen initiative officially titled the “Utah Independent Redistricting Commission and Standards Act,” commonly called Proposition 4, which reformed the redistricting process. Before the 2020 cycle, the Legislature enacted S.B. 200; plaintiffs led by the League of Women Voters of Utah argued S.B. 200 repealed and impaired the reforms in Proposition 4. On remand from this court’s earlier decision in League of Women Voters of Utah v. Utah State Legislature, 2024 UT 21, the district court granted summary judgment to plaintiffs, held S.B. 200 unconstitutional as applied to Proposition 4, declared “Proposition 4 is the law in Utah by operation of law,” and prospectively enjoined H.B. 2004, the 2021 Congressional Map.

To implement a map the district court determined would comply with Proposition 4, the court established a remedial process that includes parties proposing maps to the court, a 10-day public notice and comment period, and an evidentiary hearing on proposed maps. The Lieutenant Governor, Deidre Henderson, notified the parties that a definitive congressional map must be in place by Nov. 10, 2025, to permit orderly administration of the 2026 congressional election.

Legislative defendants — including the Utah State Legislature and the Utah Legislative Redistricting Committee and individual legislators who joined as petitioners — asked the district court to stay its injunction pending resolution of remedial proceedings and any appeals. The district court denied that motion. The Legislature then filed an emergency petition with the Utah Supreme Court under rule 19 seeking immediate relief from that denial.

In its opinion the Supreme Court walked through the procedural options the Legislature had and the compressed timeline. The court observed that an appeal under Utah Code § 78B-5-1002 (which gives defendants a right to appeal some injunctive orders that declare state laws unconstitutional) did not plainly apply to the Legislature’s challenge to a denial of a stay, and that a routine interlocutory route under Utah Rule of Appellate Procedure 5 would not have produced a sufficiently fast resolution given the map-related deadlines. The court therefore accepted the Legislature’s invocation of rule 19 for extraordinary relief but concluded the Legislature failed to meet the substantive standard for relief under rule 65B(d).

The Supreme Court emphasized that district courts retain discretion under Utah Rule of Civil Procedure 62(c) to stay or modify injunctive orders and to impose conditions that secure the rights of the nonmoving party. The court explained that Legislative Defendants had framed most of their arguments against the district court’s remedial process rather than identifying a legal error in how the district court applied the standards governing stays. Consequently, the high court concluded the Legislature had not demonstrated the district court abused its discretion in denying a stay.

The opinion notes the Supreme Court expedited consideration of the petition and that Associate Chief Justice Pearce and Justice Hagen recused themselves; two district court judges—Jennifer A. Mabey and Tony F. Graf Jr.—sat in their place for the decision.

What the decision does and does not decide: the Supreme Court’s denial is limited to the Legislature’s request for extraordinary relief from the district court’s refusal to grant a stay of the injunction; the high court did not resolve the underlying merits of the district court’s judgment regarding S.B. 200 beyond concluding the Legislature failed to show an abuse of discretion in the denial of a stay. The district court’s injunction remains in place while the remedial process and any appeals proceed.

Looking ahead, the district court’s remedial schedule and the Lieutenant Governor’s Nov. 10, 2025, date for a definitive map mean the parties face a compressed timeline to propose and litigate compliant congressional plans for the 2026 election. County clerks and candidates for Congress remain affected by the unresolved map question.

(For reference: the case is League of Women Voters of Utah v. Utah State Legislature, No. 20251057; the district court matter is No. 220901712, Third District Court, Salt Lake City.)

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