Federal Court Twist Revives GOP’s Crucial Midterm Map
Missouri’s Republican-backed congressional map is suddenly back in play after a federal judge intervened in the state’s rapidly escalating redistricting battle — less than an hour after the U.S. Supreme Court appeared to deal the GOP plan a potentially fatal blow.
Chief U.S. District Judge Stephen R. Clark issued a 14-day temporary restraining order Tuesday requiring Missouri officials to continue using the congressional districts enacted through House Bill 1 in 2025. The decision temporarily blocks the state from returning to its previous map while the federal court considers whether longer-lasting relief is warranted.
The stunning order arrived shortly after Justice Brett Kavanaugh rejected Missouri’s emergency request to pause a Missouri Supreme Court ruling against the new districts.
The result is an extraordinary collision between state and federal courts with control of a closely divided U.S. House potentially hanging in the balance.
Federal Judge Revives New Districts
The federal lawsuit was filed by Republican Rep. Bob Onder, state Sen. Rick Brattin and two Missouri voters after the state Supreme Court ordered election officials to use the congressional map adopted in 2022.
Missouri conducted its August primaries under the newer House Bill 1 districts. Clark concluded that switching maps before the November general election could nullify the practical effect of primary votes by moving hundreds of thousands of voters into districts where they had no role in selecting the nominees.
“Using a different map for the general election would wreak havoc” on Missouri’s congressional races, Clark wrote in his 13-page memorandum and order.
Clark found that the plaintiffs demonstrated a strong likelihood of success under Article I, Section 2 of the Constitution and the Equal Protection Clause. He reasoned that Missouri’s primary is an integral part of the election process and that changing district boundaries between the primary and general election could leave some voters casting ballots for nominees they did not help select.
The judge did not endorse every argument advanced by the Republican plaintiffs. In fact, he rejected their claim that allowing voters to challenge a congressional map through a referendum inherently violates the Constitution’s Elections Clause.
Instead, his order focused on the constitutional and practical consequences of changing the districts after the primary had already taken place.
GOP Map Targets Key Democratic Seat
Missouri’s Republican-controlled legislature approved the mid-decade redistricting plan during a 2025 special session. President Donald Trump had encouraged Republican-led states to revisit their congressional boundaries ahead of the midterms.
The new map divides parts of Democratic Rep. Emanuel Cleaver’s Kansas City-based 5th Congressional District among more Republican-leaning areas. If ultimately permitted to take effect, the plan could give Republicans an opportunity to expand their advantage in Missouri’s congressional delegation from six seats to seven.
Republicans argued that retaining the same districts for both stages of the election would protect the approximately 1.2 million Missourians who participated in the August primaries.
Attorney General Catherine Hanaway said the state would comply with Clark’s federal order, maintaining that changing maps between the primary and general election would be unworkable and unfair to voters.
Gov. Mike Kehoe similarly praised the ruling for providing what he called “much-needed clarity” to candidates and election officials.
State Court Raises Contempt Threat
The federal ruling did not end the fight. It immediately placed Secretary of State Denny Hoskins between two conflicting court orders.
Missouri’s Supreme Court unanimously ruled on Sept. 3 that a citizen-led referendum petition had suspended House Bill 1. The state justices concluded that the map could not take effect unless Missouri voters approved it in November and ordered Hoskins to return to the 2022 districts.
After Clark issued his federal restraining order, Hoskins instructed local election officials to use the House Bill 1 map when preparing November ballots.
Richard von Glahn, the plaintiff in the state case and executive director of People Not Politicians Missouri, responded with an emergency contempt motion. He argued that Hoskins’ instructions directly violated the state Supreme Court’s injunction.
The Missouri Supreme Court then ordered Hoskins to explain why he should not be held in contempt. The court also directed him to address whether he would refrain from taking further action until a higher court resolved the conflicting directives.
Hoskins was ordered to submit a written response by noon Wednesday and appear personally for oral arguments at 10 a.m. Thursday, Sept. 10.
Appeals Could Bring Another Twist
Opponents of the House Bill 1 map have already appealed Clark’s order to the 8th U.S. Circuit Court of Appeals and requested an immediate pause.
They contend that the federal court improperly interfered with the Missouri Supreme Court’s interpretation of state law. They have also argued that a constitutional challenge involving congressional apportionment should be considered by a three-judge federal panel rather than a single district judge.
For now, Clark’s temporary order keeps the Republican-backed map alive. But with a federal appeal underway, a contempt proceeding looming and both maps covered by conflicting injunctions, Missouri’s congressional boundaries remain far from settled.






