Alabama Legislative Black Caucus v. Alabama | |
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Argued November 12, 2014 Decided March 25, 2015 | |
Full case name | Alabama Legislative Black Caucus, et al., Appellants v. Alabama, et al.; Alabama Democratic Conference, et al., Appellants v. Alabama, et al. |
Citations | 575 U.S. 254 ( more ) 135 S. Ct. 1257; 191 L. Ed. 2d 314 |
Case history | |
Prior | 989 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 | |
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Case opinions | |
Majority | Breyer, joined by Kennedy, Ginsburg, Sotomayor, Kagan |
Dissent | Scalia, joined by Roberts, Thomas, Alito |
Dissent | Thomas |
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.
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.
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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.
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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.
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.
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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.
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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.