Alabama Legislative Black Caucus v. Alabama

Last updated

Alabama Legislative Black Caucus v. Alabama
Seal of the United States Supreme Court.svg
Argued November 12, 2014
Decided March 25, 2015
Full case nameAlabama Legislative Black Caucus, et al., Appellants v. Alabama, et al.; Alabama Democratic Conference, et al., Appellants v. Alabama, et al.
Citations575 U.S. 254 ( more )
135 S. Ct. 1257; 191 L. Ed. 2d 314
Case history
Prior989 F. Supp. 2d 1227 (M.D. Ala. 2013); probable jurisdiction noted, 572 U.S. 1149(2014).
Holding
The district court committed various legal errors, including the analysis of the racial gerrymandering claim as referring to the State "as a whole," rather than district-by-district.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
MajorityBreyer, joined by Kennedy, Ginsburg, Sotomayor, Kagan
DissentScalia, joined by Roberts, Thomas, Alito
DissentThomas

Alabama Legislative Black Caucus v. Alabama, 575 U.S. 254 (2015), was a U.S. Supreme Court decision that overturned a previous decision by a federal district court upholding Alabama's 2012 redrawing of its electoral districts. The Alabama legislature had focused on reducing the difference in population between the districts to 1% or less, while keeping the same proportion of minority voters in each district. The Alabama Legislative Black Caucus and Alabama Democratic Conference challenged this on the grounds that it was an illegal racial gerrymander, banned under the Equal Protection Clause of the Fourteenth Amendment.

The case went before a three-judge panel in federal district court. The panel characterized the arguments of the Caucus and the Conference as challenging the Alabama redistricting as a whole, with the Conference additionally challenging four specific Senate districts: 7, 11, 22, and 26. The panel held that the Caucus had standing for its claim, but dismissed the Conference's claims regarding both the state as a whole and the four districts. The Court further held that race was not the predominant factor for the redistricting as a whole or for the four districts. Finally, the panel held that, even if it was wrong and race was the predominant factor for the redistricting, the districts should still survive strict scrutiny because the act creating them was narrowly tailored to achieve the compelling state interest of avoiding racial retrogression which would prevent minority voters from electing their candidate of choice.

The Supreme Court, in a 5-4 opinion written by Justice Stephen Breyer, overturned the District Court decision. It held that racial gerrymandering claims must be considered district-by-district, rather than by looking at the state as a whole. The court may consider statewide evidence in evaluating these claims, but the complaint and remedy must concern a particular district or subset of districts. The opinion also held that the Conference had standing to bring its claims. The Court further held that equaling population between the districts is assumed to be a goal of any redistricting effort, and that a finding that the legislature was trying to equal the district population is not sufficient to dismiss claims that the legislature improperly considered race when drawing district lines. Finally, the Court rejected Alabama's claim that Section Five of the Voting Rights Act of 1965 compelled them to maintain the same percentage of minority voters in each district. Section Five only bars legislative action that would diminish the ability of a minority group to elect their candidate of choice. The Court then vacated the previous holding of the District Court and remanded the case for further consideration.

Related Research Articles

Wesberry v. Sanders, 376 U.S. 1 (1964), was a landmark U.S. Supreme Court case in which the Court ruled that districts in the United States House of Representatives must be approximately equal in population. Along with Baker v. Carr (1962) and Reynolds v. Sims (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies.

Easley v. Cromartie, 532 U.S. 234 (2001), is an appeal of the United States Supreme Court case Hunt v Cromartie. The case defendant is Mike Easley, who became North Carolina governor following Jim Hunt. The court's ruling on April 18, 2001, stated that redistricting for political reasons did not violate Federal Civil Rights Law banning race-based gerrymandering..

Baker v. Carr, 369 U.S. 186 (1962), was a landmark United States Supreme Court case in which the Court held that redistricting qualifies as a justiciable question under the equal protection clause of the Fourteenth Amendment, thus enabling federal courts to hear Fourteenth Amendment-based redistricting cases. The court summarized its Baker holding in a later decision as follows: "the Equal Protection Clause of the Fourteenth Amendment limits the authority of a State Legislature in designing the geographical districts from which representatives are chosen either for the State Legislature or for the Federal House of Representatives.". The court had previously held in Gomillion v. Lightfoot that districting claims over racial discrimination could be brought under the Fifteenth Amendment.

Reynolds v. Sims, 377 U.S. 533 (1964), was a landmark United States Supreme Court case in which the Court ruled that the electoral districts of state legislative chambers must be roughly equal in population. Along with Baker v. Carr (1962) and Wesberry v. Sanders (1964), it was part of a series of Warren Court cases that applied the principle of "one person, one vote" to U.S. legislative bodies.

Miller v. Johnson, 515 U.S. 900 (1995), was a United States Supreme Court case concerning "affirmative gerrymandering/racial gerrymandering", where racial minority-majority electoral districts are created during redistricting to increase minority Congressional representation.

<span class="mw-page-title-main">North Carolina's congressional districts</span> U.S. House districts in the state of North Carolina

North Carolina is currently divided into 14 congressional districts, each represented by a member of the United States House of Representatives. After the 2000 census, the number of North Carolina's seats was increased from 12 to 13 due to the state's increase in population. In the 2022 elections, per the 2020 United States census, North Carolina gained one new congressional seat for a total of 14.

<span class="mw-page-title-main">Alabama's congressional districts</span>

The U.S. state of Alabama is currently divided into seven congressional districts, each represented by a member of the United States House of Representatives.

<i>Shaw v. Reno</i> 1993 US Supreme Court gerrymandering case

Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering. After the 1990 census, North Carolina qualified to have a 12th district and drew it in a distinct snake-like manner in order to create a “majority-minority” Black district. From there, Ruth O. Shaw sued this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the clause of equal protection. In contrast, Reno, the Attorney General, argued that the district would allow for minority groups to have a voice in elections. In the decision, the court ruled in a 5–4 majority that redistricting based on race must be held to a standard of strict scrutiny under the equal protection clause and on the basis that it violated the fourteenth Amendment because it was drawn solely based on race.

Wright v. Rockefeller, 376 U.S. 52 (1964), was a case in which the Supreme Court of the United States held that in cases involving allegations of improper racial gerrymandering, where the evidence was "equally, or more, persuasive" that racial considerations had not motivated the State Legislature, the Court will give deference to the findings of the District Court.

Vieth v. Jubelirer, 541 U.S. 267 (2004), was a United States Supreme Court ruling that was significant in the area of partisan redistricting and political gerrymandering. The court, in a plurality opinion by Justice Antonin Scalia and joined by Chief Justice William Rehnquist and Justices Sandra Day O'Connor and Clarence Thomas, with Justice Anthony Kennedy concurring in the judgment, upheld the ruling of the District Court in favor of the appellees that the alleged political gerrymandering was not unconstitutional. Subsequent to the ruling, partisan bias in redistricting increased dramatically in the 2010 redistricting round.

Georgia v. Ashcroft, 539 U.S. 461 (2003), is a United States Supreme Court case in which the Court found that a three-judge federal district court panel did not consider all of the requisite relevant factors when it examined whether the 2001 Georgia State Senate redistricting plan resulted in retrogression of black voters’ effective exercise of the electoral franchise in contravention of Section 5 of the Voting Rights Act. Section 5, which only applies to those states or political subdivisions that are considered “covered” under Section 4(b) of the VRA, requires that before any change in voting procedure can take effect, it must be precleared by the federal government by a demonstration that the change would not "lead to a retrogression in the position of racial minorities with respect to their effective exercise of the electoral franchise.” The Court held that the district court analysis was incorrect “because it focused too heavily on the ability of the minority group to elect a candidate of its choice in the [safe] districts,” without giving proper consideration to other factors such as the state's creation of additional influence and coalition districts. Accordingly, the Supreme Court vacated and remanded the case to the district court to examine the facts using the new standard announced in its opinion.

Bush v. Vera, 517 U.S. 952 (1996), is a United States Supreme Court case concerning racial gerrymandering, where racial minority majority-electoral districts were created during Texas' 1990 redistricting to increase minority Congressional representation. The Supreme Court, in a plurality opinion, held that race was the predominant factor in the creation of the districts and that under a strict scrutiny standard the three districts were not narrowly tailored to further a compelling governmental interest.

<span class="mw-page-title-main">Gerrymandering in the United States</span> Setting electoral district boundaries to favor specific political interests in legislative bodies

Gerrymandering is the practice of setting boundaries of electoral districts to favor specific political interests within legislative bodies, often resulting in districts with convoluted, winding boundaries rather than compact areas. The term "gerrymandering" was coined after a review of Massachusetts's redistricting maps of 1812 set by Governor Elbridge Gerry noted that one of the districts looked like a mythical salamander.

<span class="mw-page-title-main">2020 United States redistricting cycle</span>

The 2020 United States redistricting cycle is in progress following the completion of the 2020 United States census. In all fifty states, various bodies are re-drawing state legislative districts. States that are apportioned more than one seat in the United States House of Representatives are also drawing new districts for that legislative body.

Gill v. Whitford, 585 U.S. ___ (2018), was a United States Supreme Court case involving the constitutionality of partisan gerrymandering. Other forms of gerrymandering based on racial or ethnic grounds had been deemed unconstitutional, and while the Supreme Court had identified that extreme partisan gerrymandering could also be unconstitutional, the Court had not agreed on how this could be defined, leaving the question to lower courts to decide. That issue was later resolved in Rucho v. Common Cause, in which the Court decided that partisan gerrymanders presented a nonjusticiable political question.

Bethune-Hill v. Virginia State Bd. of Elections, 580 U.S. ___ (2017), was a case in which the United States Supreme Court evaluated whether Virginia's legislature – the Virginia General Assembly – violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution by considering racial demographics when drawing the boundaries of twelve of the state's legislative districts.

Abbott v. Perez, 585 U.S. ___ (2018), was a United States Supreme Court case dealing with the redistricting of the state of Texas following the 2010 Census.

Rucho v. Common Cause, No. 18-422, 588 U.S. ___ (2019) is a landmark case of the United States Supreme Court concerning partisan gerrymandering. The Court ruled that while partisan gerrymandering may be "incompatible with democratic principles", the federal courts cannot review such allegations, as they present nonjusticiable political questions outside the remit of these courts.

<span class="mw-page-title-main">Redistricting in North Carolina</span>

Redistricting in North Carolina has been a controversial topic due to allegations and admissions of gerrymandering.

Virginia House of Delegates v. Bethune-Hill, 587 U.S. ___ (2019), was a case argued before the United States Supreme Court on March 18, 2019, in which the Virginia House of Delegates appealed against the decision in 2018 by the district court that 11 of Virginia's voting districts were racially gerrymandered, and thus unconstitutional. The Court held the "Virginia House of Delegates lacks standing to file this appeal, either representing the state's interests or in its own right." In other words, the court upheld the decision made by a federal district court ruling in June 2018 that 11 state legislative districts were an illegal racial gerrymander. This was following a previous (2017) case, Bethune-Hill v. Virginia State Bd. of Elections.

References