On April 18, the Virginia voters who argued that members of the lower house of the legislature cannot serve until January 2024 filed this brief in Goldman v Brink, e.d., 3:21cv-420.

Members of the lower house of the Virginia legislature were elected in November 2021, from districts that were drawn using the 2010 census. Normally they would serve two-year terms, but some voters filed that it violates the U.S. Constitution to retain the old districts that long after the new 2020 census.