No. The map is not illegal. The Voting Rights Act is meant to stop states from unfairly weakening a group's voting power, not to force states to give a group the maximum possible power. The main question is whether the system is fair overall. Since Florida's map gave Hispanic voters a number of districts that was proportional to their population, it gave them a fair opportunity to elect their chosen candidates. A map isn't automatically bad for not being perfect, and it isn't automatically good just for being proportional, but proportionality is very strong evidence that the map is fair.

No. The law doesn't require map-drawers to squeeze out every last possible district for a minority group. The most important thing is fairness, and proportionality is a key piece of evidence for that. If a map isn't proportional, that's a red flag. If it is proportional, that's a good sign, but courts still have to check everything to make sure there's no hidden unfairness.

No. The lower court was wrong to think the goal was just to make as many minority districts as possible. We have to be careful about drawing maps based on race. The Constitution wants us to move beyond racial divisions, and intentionally separating voters by race is a dangerous path, even if it's done with good intentions.

Yes, the lower court was wrong to find the House district plan violated the Voting Rights Act just because it didn't maximize the possible number of minority-majority districts. The percentage of minority-majority districts compared to the minority population matters, but isn't the only factor. The lower court's decision is partly agreed with and partly reversed. The Rooker-Feldman rule doesn't stop this federal case by people who weren't in the state case.

Agrees with the main opinion that the Voting Rights Act doesn't require maximizing possible minority-majority districts, and that comparing minority-majority districts to minority population is relevant but not the only factor in seeing if minority votes are weakened. Emphasizes the Rooker-Feldman rule doesn't apply here.

Agrees with some of the main opinion and the overall judgment. Points out potential constitutional issues with race-based districting and the need to comply with equal protection under the law. Agrees the Rooker-Feldman rule doesn't apply to the new parties in federal court here.

Disagrees, arguing that a districting plan can't be challenged under this part of the Voting Rights Act at all, and questions if the Rooker-Feldman rule applies.

The Rooker-Feldman doctrine states that: a losing party in state court is barred from seeking what in substance would be appellate review of the state judgment in a United States District Court, based on the losing party's claim that the state judgment itself violates the loser's federal rights.

—proportionality, or lack thereof, between the number of minority-controlled districts and the minority's share of the state's relevant population. The Supreme Court has indicated that, while rough proportionality does not automatically protect a state from liability under § 2, nor does § 2 require a state to maximize the possible number of majority-minority districts …

Also, "[t] he Rooker-Feldman doctrine does not apply to bar a suit in federal court brought by a party that was not a party in the preceding action in state court."

"No single statistic provides courts with a shortcut to determine whether" a voting change retrogresses from the benchmark.

The Supreme Court has repeatedly emphasized that "the Gingles factors cannot be applied mechanically and without regard to the nature of the claim."

—"[w] hen applied to a claim that single-member districts dilute minority votes, the first Gingles condition requires the possibility of creating more than the existing number of reasonably compact districts with a sufficiently large minority population to elect candidates of its choice."

—explaining in the context of § 2 that although "society's racial and ethnic cleavages sometimes necessitate majority-minority districts to ensure equal political and electoral opportunity, that should not obscure the fact that there are communities in which minority citizens are able to form coalitions with voters from other racial and ethnic groups, having no need to be a …

Vote dilution exists when "members of a minority group have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice."

Minorities are not immune from the obligation to "pull, haul, and trade to find common political ground."

No. A districting plan that provides minority voters with a number of districts in which they form an effective majority that is substantially proportional to their share of the population does not violate § 2 of the Voting Rights Act, absent other evidence that the plan denies equal political opportunity. The three threshold conditions from Thornburg v. Gingles are necessary but not sufficient to prove vote dilution in single-member districting cases. The ultimate inquiry is a totality of the circumstances analysis, and proportionality is a key circumstance to be considered. The Voting Rights Act is meant to prevent political 'famine,' not to guarantee a political 'feast,' and a failure to maximize the number of majority-minority districts is not, by itself, the measure of vote dilution. Similarly, proportionality is not a 'safe harbor' that immunizes a plan from challenge, as other discriminatory practices could still result in a denial of equal opportunity. Here, the substantial proportionality achieved by Florida's plan, despite a history of discrimination and bloc voting, indicates that Hispanic voters were not denied an equal opportunity to participate in the political process.

No. The Court correctly holds that § 2 of the Voting Rights Act does not require states to maximize the number of majority-minority districts. The opinion's central teaching is that proportionality is always relevant evidence but is never dispositive. A lack of proportionality is probative evidence of dilution, but the presence of proportionality is not a safe harbor for states, as a court must always examine the totality of the circumstances to ensure minority voters have equal opportunity to participate in the political process. This approach properly balances the goals of the Act without creating a rigid maximization rule.

No. The District Court's equation of vote dilution with the failure to maximize majority-minority districts was erroneous. While proportionality is relevant to a § 2 claim, placing undue emphasis on it risks defeating the goals of the Voting Rights Act. It is critical to recognize that explicit race-based districting raises the most serious constitutional questions under the Equal Protection Clause. Governmental actions that sort voters by race tend to entrench the very stereotypes the Constitution is set against, and redistricting must comply with the overriding demands of racial neutrality.

Yes, the District Court erred in finding a violation of Section 2 in the House districts because it equated dilution with failure to maximize the number of majority-minority districts. Proportionality is relevant but not dispositive. The judgment is affirmed in part and reversed in part. The Rooker-Feldman doctrine does not bar federal court suits by parties not involved in the original state court action.

Concurs with the majority that Section 2 does not require maximization of minority voting strength and that proportionality is relevant but not dispositive evidence in determining vote dilution. Emphasizes that the Rooker-Feldman doctrine is not applicable to parties not involved in state court proceedings.

Concurs in part and in the judgment, emphasizing the constitutional implications of race-based districting and the need for compliance with the Equal Protection Clause. Acknowledges that the Rooker-Feldman doctrine does not apply to new parties in federal court.

Dissents, arguing that an apportionment plan is not a 'standard, practice, or procedure' that may be challenged under Section 2 of the Voting Rights Act and questions the applicability of the Rooker-Feldman doctrine.

Johnson v. De Grandy

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