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Alexander v. South Carolina State Conference of the NAACP

Supreme Court of the United States · 2024 · Constitutional Law

Constitutional LawEqual ProtectionRedistrictingRacial GerrymanderingVote Dilutionracial gerrymanderingvote dilutionequal protection

Facts

Following the 2020 census, South Carolina had to move population out of overpopulated District 1 and into underpopulated District 6. The Republican-controlled legislature openly sought to make District 1 more safely Republican, and its mapmaker used political data from the 2020 presidential election while denying that race was used to draw the enacted map. The enacted plan increased District 1's projected Republican vote share while its black voting-age population remained about 17%, and many Charleston precincts moved from District 1 to District 6 were heavily Democratic. The challengers offered no direct evidence of racial targeting and no alternative map that both achieved the legislature's partisan goal and maintained a higher BVAP in District 1.

Issue

Whether the District Court clearly erred in finding that race predominated over politics in South Carolina's drawing of Congressional District 1, and whether the District Court's related racial vote-dilution ruling could stand on the same factual findings.

Rule

To prove an unconstitutional racial gerrymander, a plaintiff must show that race was the predominant factor motivating the legislature's placement of a significant number of voters in or out of a district, meaning the State subordinated traditional race-neutral districting criteria to racial considerations. When race and partisanship are highly correlated, the plaintiff must disentangle race from politics and rule out the competing explanation that politics drove the district's lines, while courts begin with a presumption that the legislature acted in good faith. In circumstantial-evidence cases, an alternative map showing the State could have achieved its legitimate political objectives with significantly greater racial balance can be key evidence, and failure to provide one may support an adverse inference.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

After the census, the legislature in Georgia redraws a congressional district centered on Savannah to make it more reliably Republican. Black voters in the area overwhelmingly support Democrats. Challengers show that the enacted district removed several heavily Black neighborhoods and that the district’s Black voting-age population dropped, but they offer no direct statements by mapmakers and no evidence ruling out the legislature’s stated partisan objective.

On an Equal Protection racial-gerrymandering claim, which is the strongest answer?

Explanation. A plaintiff must prove that race was the predominant factor motivating placement of a significant number of voters and that traditional race-neutral criteria were subordinated to racial considerations. When race and partisanship are tightly correlated, the plaintiff must disentangle race from politics and rule out the competing explanation that politics drove the lines. Without direct evidence or proof excluding the partisan explanation, the claim likely fails. (Derived from Alexander v. South Carolina State Conference of the NAACP (n.d.).)