United States v. Hays, 515 U.S. 737, 6 (1995)

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742

UNITED STATES v. HAYS

Opinion of the Court

Act 42's District 4 ran in a zigzag fashion along the northern and eastern borders of the State, Act 1's District 4 begins in the northwestern part of the State and runs southeast along the Red River until it reaches Baton Rouge. For present purposes, the most significant difference between the two district maps is that in Act 42, part of Lincoln Parish was contained in District 4, while in Act 1, Lincoln Parish is entirely contained in District 5.

On remand, the District Court allowed appellees to amend their complaint to challenge Act 1's constitutionality and permitted the United States to intervene as a defendant. It then held another 2-day hearing and concluded, largely for the same reasons that it had invalidated Act 42, that Act 1 was unconstitutional. See Hays v. Louisiana, 862 F. Supp. 119 (WD La. 1994) (Hays II). The court enjoined the State from conducting any elections pursuant to Act 1, substituted its own districting plan, and denied the State's motion for a stay of judgment pending appeal.

Louisiana and the United States appealed directly to this Court. We stayed the District Court's judgment, 512 U. S. 1273 (1994), and noted probable jurisdiction, 513 U. S. 1056 (1994).

II

The District Court concluded that appellees had standing to challenge Act 42, see Hays I, 839 F. Supp., at 1192, but did not reconsider standing when faced with Act 1. The question of standing is not subject to waiver, however: "[W]e are required to address the issue even if the courts below have not passed on it, and even if the parties fail to raise the issue before us. The federal courts are under an independent obligation to examine their own jurisdiction, and standing 'is perhaps the most important of [the jurisdictional] doctrines.' " FW/PBS, Inc. v. Dallas, 493 U. S. 215, 230-231 (1990) (citations omitted).

It is by now well settled that "the irreducible constitutional minimum of standing contains three elements. First,

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