In a watershed 2015 referendum, Ohioans decisively approved a state constitutional amendment that prohibited partisan gerrymandering of General Assembly districts and created the Ohio Redistricting Commission. Though the amendment mandated that the Commission draw proportional maps not primarily designed to favor or disfavor a political party, the Commission—composed of partisan elected officials—repeatedly enacted unconstitutional, heavily gerrymandered districting plans in blatant defiance of the Ohio Supreme Court.

After the Ohio Supreme Court struck down four of the Commission’s plans, leaving Ohio without state House and Senate maps just months before the 2022 general election, a group of voters sued in the U.S. District Court for the Southern District of Ohio, arguing that federal judicial intervention was needed to protect Ohioans’ voting rights. In this case, Gonidakis v. LaRose, a three-judge panel imposed one of the Commission’s invalidated gerrymanders. By rendering this misguided decision, the panel disregarded the anti-gerrymandering provisions of the Ohio Constitution, thwarted the will of the voters, and created an incentive for the Commission to simply defy adverse state court rulings.

This Article critiques Gonidakis and examines when and how federal courts should intervene if state-level commission-based redistricting processes go awry. It argues that when a federal court decides a case in which a state court has struck down a map created by a redistricting commission, the federal court should usually—but not always—defer to the state court ruling.