Illinois Gerrymandering Lawsuit: McCombie and Ives v. Pritzker

The Illinois gerrymandering lawsuits currently on the books fall into two buckets: a state-court challenge to the 2021 legislative maps that the Illinois Supreme Court threw out in April 2025 on timing grounds, and a federal challenge filed in May 2026 that targets the Illinois Voting Rights Act of 2011 itself. Neither case has produced a ruling on whether the maps are actually gerrymandered. The state case never reached the merits, and the federal case is still in its opening stages.

McCombie v. Illinois State Board of Elections

In early 2025, House Republican Leader Tony McCombie and four voters asked the Illinois Supreme Court for leave to file an original action challenging the legislative maps enacted in 2021. The plaintiffs argued the maps violated two provisions of the Illinois Constitution: Article IV, Section 3(a), which requires districts to be “compact, contiguous and substantially equal in population,” and Article III, Section 3, which guarantees that “all elections shall be free and equal.” Plaintiffs read that second clause as a “political fairness” requirement.1FindLaw. McCombie v. Illinois State Board of Elections

The state-court venue mattered. In 2019, the U.S. Supreme Court held in Rucho v. Common Cause that federal courts cannot decide partisan gerrymandering claims, pointing to state courts and state constitutions as the proper forum. McCombie’s suit was Illinois’s first serious test of that path.

What Republicans Argued

On compactness, plaintiffs alleged that more than half of the state’s current House districts were less compact than a district the Illinois Supreme Court had struck down in 1981, and they cited the Princeton Gerrymandering Project, which had given the Illinois House map an “F” grade for compactness.2Capitol News Illinois. Supreme Court Rules House Republicans Waited Too Long to Challenge Maps

On partisan intent, plaintiffs relied on statements from the August 31, 2021, House floor debate. Representative Mazzochi accused Democrats of drawing maps to “protect your own political power,” and Representative Spain challenged then-Leader Lisa Hernandez on the map’s compactness score, which he calculated at 0.26 on a scale where 1.0 represents good compactness.3Illinois Courts. McCombie v. Illinois State Board of Elections – Defendants’ Filing Brief The plaintiffs said they needed data from two complete election cycles to prove a pattern of partisan entrenchment, drawing on federal precedent that had used multi-cycle analysis before Rucho.

How the Court Ruled

The Illinois Supreme Court denied the motion on April 9, 2025, without reaching the substance. A five-justice majority held the challenge was barred by laches, an equitable doctrine that prevents a party from bringing a claim after an unreasonable delay that prejudices the other side.4Illinois Courts. McCombie v. Illinois State Board of Elections, 2025 IL 131480

The court said the filing lacked “due diligence” because it came more than three years and four months after the maps were signed and after two election cycles had already run in 2022 and 2024. Every previous redistricting challenge under the 1970 Illinois Constitution had been filed within days or weeks of enactment, the court noted.1FindLaw. McCombie v. Illinois State Board of Elections The 2020 census data, five years old, could now be considered “stale,” and letting the case go forward would create “uncertainty for voters and officeholders alike” about the finality of any plan.5Illinois State Bar Association. Quick Takes on Illinois Supreme Court Opinion

Democratic intervenors, including House Speaker Emanuel “Chris” Welch and Senate President Don Harmon, had argued that hearing the challenge mid-decade would invite parties to “wait until they have a wave election and use their best election results to justify a partisan challenge to the legislative map.”6Capitol News Illinois. Democrats Argue Republicans Waited Too Long to File Latest Redistricting Lawsuit The court found that argument persuasive. No party appealed.

The Dissent

Justice David Overstreet dissented alone. He argued the majority had it backwards. Partisan gerrymandering claims, unlike compactness challenges, need multi-cycle election data to prove, and federal courts had directed such claims to state courts in Rucho, yet the Illinois Supreme Court had never adjudicated a partisan gerrymandering case or set out what a viable one would look like.4Illinois Courts. McCombie v. Illinois State Board of Elections, 2025 IL 131480 Overstreet called the majority’s due-diligence reasoning “disingenuous” and objected that the court had raised laches on its own rather than in response to a party’s argument, which he said amounted to the court “choosing sides.”7Legal Newsline. GOP Can’t Challenge Gerrymandered Dem District Maps Justice Lisa Holder White did not participate in the decision.8Chicago Tribune. Democratic-Led Illinois Supreme Court Rejects GOP Challenge to Legislative Maps

The practical effect: the 2021 legislative maps stand, and Illinois still has no state-court precedent defining what a partisan gerrymander looks like under its constitution.

The Earlier Federal Challenges

The state-court route existed because the federal route had already closed. Three federal lawsuits were filed almost immediately after the 2021 maps were enacted and consolidated before a three-judge panel in the Northern District of Illinois: McConchie v. Illinois State Board of Elections, East St. Louis Branch NAACP v. Illinois State Board of Elections, and Contreras v. Illinois State Board of Elections.9Brennan Center for Justice. Redistricting Litigation Roundup

Republican leaders alleged malapportionment based on the initial maps’ use of American Community Survey estimates instead of decennial census counts. The East St. Louis NAACP and allied civil rights groups alleged racial gerrymandering and dilution of Black voting strength, focused on House District 114, which had been represented by a Black legislator since 1975 and is the only state House district in southern Illinois with Black representation. Plaintiffs alleged that one-fifth of the district’s Black voting-age population had been moved out and replaced with white voters to protect white Democratic incumbents in neighboring districts.10Lawyers’ Committee for Civil Rights Under Law. Illinois Redistricting Plan Undermines the Rights of Black Voters in East St. Louis MALDEF separately argued that Latino population growth should have produced nine House districts and four Senate districts with Latino-opportunity representation, while the enacted maps provided only six House districts.11MALDEF. MALDEF Updates Illinois Redistricting Lawsuit to Include Federal VRA Violation

On October 19, 2021, the three-judge court held that the June legislative maps drawn from ACS estimates violated the Equal Protection Clause as malapportioned. Then on December 30, 2021, the same panel rejected all remaining challenges to the revised September 2021 maps. On the Voting Rights Act claims, the court found significant evidence of crossover voting that defeated vote-dilution arguments. On the racial gerrymandering claims, it concluded that the legislature’s primary motivation was “partisan politics—a legally acceptable criterion” rather than race.12Loyola Law School Redistricting. McConchie v. Scholz – Final Order No party appealed.9Brennan Center for Justice. Redistricting Litigation Roundup

That finding, that the maps were partisan rather than racial, is what left the door open to a state partisan gerrymandering case and pushed McCombie to file where he did.

Ives v. Pritzker

The newest lawsuit takes a different angle. On May 8, 2026, former Republican state Representative Jeanne Ives filed Ives v. Pritzker in the U.S. District Court for the Central District of Illinois, seeking to strike down the Illinois Voting Rights Act of 2011.13Public Interest Legal Foundation. Ives v. Pritzker – Complaint

The Illinois Voting Rights Act requires state legislative and representative districts to be drawn “to create crossover districts, coalition districts, or influence districts” that give racial and language minorities the opportunity to elect preferred candidates or influence outcomes. The statute defines a crossover district as one where a racial minority is large enough to elect its preferred candidate with help from supportive majority voters, a coalition district as one where multiple minority groups can combine to elect a preferred candidate, and an influence district as one where a minority group can influence the outcome even if it cannot elect its own candidate.14Illinois General Assembly. Illinois Voting Rights Act of 2011 – Full Text

Ives, represented by the Public Interest Legal Foundation, argues those requirements force mapmakers to sort voters by race, violating the Fifteenth Amendment and Section 2(a) of the federal Voting Rights Act.15Democracy Docket. Right-Wing Group Sues Illinois in First Post-Callais Attack on a State Voting Rights Act The complaint asks the court to declare the state law unconstitutional and permanently block state officials from enforcing it.13Public Interest Legal Foundation. Ives v. Pritzker – Complaint

The case leans on the U.S. Supreme Court’s April 2026 decision in Louisiana v. Callais, which struck down Louisiana’s congressional map as an unconstitutional racial gerrymander. In Callais, the Court held that while compliance with Section 2 of the federal Voting Rights Act can justify using race in redistricting, the VRA must be “properly construed” and does not authorize race-based line-drawing to achieve proportional representation or to overcome voting patterns that correlate with partisan rather than racial preference.16Supreme Court of the United States. Louisiana v. Callais Ives v. Pritzker is described as the first major challenge to a state voting rights act after Callais.15Democracy Docket. Right-Wing Group Sues Illinois in First Post-Callais Attack on a State Voting Rights Act

The Public Interest Legal Foundation was founded by J. Christian Adams, who served on President Trump’s 2017 voter fraud commission, and has separately challenged California’s voter-approved congressional map on similar racial-redistricting grounds.17Democracy Docket. Right-Wing Legal Group Sues to Block California’s Voter-Approved Congressional Map

Where the Cases Stand

The 2021 legislative and congressional maps remain in force. McCombie is over. Ives v. Pritzker is in its earliest stages; Governor Pritzker filed an unopposed motion for an extension of time to respond on May 26, 2026, and no substantive rulings have been issued.18The ARP. Ives v. Pritzker

One boundary worth noting: none of the pending gerrymandering lawsuits challenges the Illinois congressional map. National Democratic leaders pressed the General Assembly in late 2025 to redraw the congressional lines to add a Democratic-leaning seat, but that effort met resistance from the Illinois Senate Black Caucus and available reporting does not indicate the General Assembly adopted new congressional lines.19Capitol News Illinois. Jeffries Illinois Redistricting Push Meets Cool Reception in Springfield That is a political fight, not a courtroom one.