Easley v. Cromartie

Supreme Court of the United States
532 U.S. 223, 121 S. Ct. 1475, 149 L. Ed. 2d 420 (2001)

ELI5:

Rule of Law:

A state legislature's redistricting plan does not violate the Equal Protection Clause when political considerations, rather than race, predominantly explain the district's boundaries, even when race and political affiliation are highly correlated.

Facts:

North Carolina redrew Congressional District 12's boundaries in 1997 after the Supreme Court found the 1992 boundaries unconstitutional for using race as the predominant factor
The new district contained a heavily African-American voting population
African-American voters in North Carolina overwhelmingly voted Democratic (95-97% of the time)
The district had an unusual shape and split several towns and counties
The legislature claimed it drew the boundaries to create a safe Democratic seat, not for racial reasons
White registered Democrats crossed over to vote Republican more often than African-American Democrats

Procedural Posture:

The Supreme Court previously found North Carolina's 1992 boundaries for District 12 unconstitutional in Shaw v. Hunt
North Carolina redrew the district boundaries in 1997
Plaintiffs filed suit challenging the new boundaries as racially gerrymandered
A three-judge District Court granted summary judgment for plaintiffs
The Supreme Court reversed in Hunt v. Cromartie, finding genuine issues of material fact
On remand, the District Court held a 3-day trial
The District Court again ruled that the boundaries violated the Equal Protection Clause
The State appealed directly to the Supreme Court

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Issue:

Did North Carolina violate the Equal Protection Clause by using race as the predominant factor in drawing the 1997 boundaries of Congressional District 12?

Opinions:

Majority - Justice Breyer

The District Court's conclusion that race predominated in the drawing of District 12's boundaries is clearly erroneous. The challengers failed to meet their demanding burden of proof to show that the facially neutral redistricting plan was unexplainable on grounds other than race. Given the high correlation between race and political affiliation in North Carolina, where African-Americans vote Democratic 95-97% of the time, the evidence does not demonstrate that racial considerations predominated over legitimate political objectives. The District Court improperly relied on voter registration data rather than actual voting behavior, and failed to adequately consider that the legislature could have been pursuing the legitimate political goal of creating a safe Democratic seat. When racial identification correlates highly with political affiliation, challengers must show that the legislature could have achieved its legitimate political objectives through alternative means that would have brought about significantly greater racial balance.

Dissenting - Justice Thomas

The District Court's findings should be affirmed. The trial court carefully examined extensive evidence over three days and concluded that race, not politics, drove the redistricting decision. The majority improperly substitutes its own judgment for that of the District Court, which was in a better position to evaluate the evidence. The legislature's own statements and internal communications, including an email from a legislative staffer and statements from the redistricting leader, provide direct evidence that racial considerations played a predominant role in the districting decision.

Analysis:

This decision establishes a high evidentiary burden for plaintiffs challenging redistricting plans in jurisdictions where race and political affiliation are highly correlated. The Court emphasizes that courts must exercise extraordinary caution when reviewing legislative redistricting decisions, particularly when the state articulates a legitimate political explanation. The ruling makes it significantly more difficult to prove racial gerrymandering claims when African-American voters overwhelmingly support one political party, as the legislature can claim it was pursuing partisan rather than racial objectives. The Court requires challengers to demonstrate not just that race was considered, but that it predominated over all other factors, and that alternative districting plans could have achieved the same political goals with greater racial balance.

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