Hunt v. Cromartie
526 U.S. 541 (1999)
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Rule of Law:
When plaintiffs in a racial gerrymandering case present circumstantial evidence that a legislative districting plan was drawn with a predominant racial motive, summary judgment for the plaintiffs is inappropriate if the state provides a credible, alternative explanation that political affiliation was the predominant motive, thereby creating a genuine issue of material fact.
Facts:
- In response to a prior plan being invalidated, the North Carolina General Assembly enacted a new congressional redistricting plan in 1997.
- The 1997 plan redrew the 12th Congressional District, which was previously a majority-black district.
- Under the new plan, District 12 was no longer majority-black, with its black population reduced to approximately 47%.
- The district retained its 'snakelike' shape, was geographically narrower and shorter than before, and largely followed the Interstate-85 corridor.
- The redrawn district connected urban population centers in Greensboro, Winston-Salem, and Charlotte, and it split 6 counties.
- State officials claimed their motivation was political: to create a strong Democratic district, protect incumbents, and maintain the state's 6-6 partisan balance in its congressional delegation.
- In North Carolina, there is a high correlation between the race of voters and their party preference, with black voters overwhelmingly favoring the Democratic Party.
Procedural Posture:
- Appellees (voters led by Cromartie) filed suit against state officials in the U.S. District Court for the Eastern District of North Carolina.
- The suit challenged North Carolina's 1997 congressional redistricting plan, alleging that the 12th Congressional District constituted an unconstitutional racial gerrymander.
- The parties filed competing motions for summary judgment before a three-judge panel of the District Court.
- Without discovery or an evidentiary hearing, the District Court granted summary judgment for the appellees (plaintiffs), finding the district was a product of unconstitutional racial gerrymandering.
- The District Court entered an injunction preventing elections from being held under the 1997 plan.
- The state officials (appellants) filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does a state's creation of an irregularly shaped congressional district with a high concentration of minority voters violate the Equal Protection Clause as a racial gerrymander when the state presents evidence that its predominant motive was political, creating a genuine issue of material fact regarding legislative intent?
Opinions:
Majority - Justice Thomas
No. When the state provides a credible, non-racial explanation for a districting plan, such as political motivation, and supports it with evidence, a genuine issue of material fact exists that precludes summary judgment. Here, the state provided significant evidence that it subordinated traditional districting principles to political, not racial, considerations. The state's expert, Dr. Peterson, conducted a thorough analysis of all 234 boundary segments and concluded that the data supported a political explanation as well as, or better than, a racial one by showing that the legislature consistently chose more heavily Democratic precincts over more heavily black precincts where the two diverged. Given the high correlation between race and party preference, evidence of racial sorting is not dispositive when it also correlates with political sorting. Because the state's evidence of political motivation must be taken as true at the summary judgment stage, the District Court erred by resolving this disputed factual issue of legislative motive without a trial.
Concurring - Justice Stevens
No. Summary judgment was inappropriate because the state's evidence of political motivation was substantial. A district's bizarre configuration is a traditional hallmark of both political and racial gerrymandering, so the shape itself does not resolve which motive was predominant. The District Court's reliance on party registration data was misplaced, as actual voting results are far more probative of political preference, especially in the South where many registered Democrats vote for Republican candidates. The state's evidence, including affidavits from legislators and analysis of election results, strongly supported the conclusion that the legislature's primary goal was to create a district of loyal Democrats, who happen to be disproportionately black, which is not a constitutional violation.
Analysis:
This decision significantly raises the evidentiary bar for plaintiffs in racial gerrymandering cases, particularly at the summary judgment stage. By holding that a credible political explanation can defeat a motion for summary judgment, the Court makes it more difficult to prove that race was the 'predominant factor' when race and political affiliation are highly correlated. The ruling forces plaintiffs to proceed to a full trial to discredit the state's asserted political motive, making such litigation more costly and time-consuming. It solidifies the principle that conscious awareness of race in a political gerrymander is not, by itself, unconstitutional, reinforcing a distinction between permissible political gerrymandering and impermissible racial gerrymandering.
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