In a 2015 case upholding the constitutionality of Arizona's independent redistricting commission, a Supreme Court majority consisting of the four liberal justices and Justice Anthony Kennedy rejected the independent state legislature theory.
Sources
- What's at Stake When the Supreme Court Argues Moore v. ... (propublica.org)
- https://www.scotusblog.com/?p=500835 (scotusblog.com)
- https://www.pbs.org/newshour/politics/justices-uphold-arizonas-system-redistricting (pbs.org)
- https://ballotpedia.org/Arizona_State_Legislature_v._Arizona_Independent_Redistricting_Commission (ballotpedia.org)
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