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League of United Latin American Citizens v. Perry

Supreme Court of the United States · 2006 · Constitutional Law

Constitutional LawRedistrictingPolitical GerrymanderingVoting Rights Act § 2mid-decade redistrictingpolitical gerrymanderingmanageable standardrepresentational rights

Facts

Texas enacted Plan 1374C in 2003 to replace a prior court-drawn congressional map. Appellants argued the statewide plan was an unconstitutional partisan gerrymander and that specific districts violated § 2 of the Voting Rights Act. In District 23, the legislature removed many Latino voters from a district where Latinos had become politically effective and added largely Anglo Republican voters, reducing the Latino citizen voting-age population from 57.5% to 46%. The State argued that new District 25 offset any loss in District 23, but District 25 joined far-flung Latino populations from Austin and the Rio Grande Valley with differing needs and interests.

Issue

Whether Texas's 2003 mid-decade congressional redistricting plan was an unconstitutional partisan gerrymander, and whether the redrawing of District 23 and District 24 violated § 2 of the Voting Rights Act. More specifically, the Court considered whether mid-decade partisan motivation alone provides a manageable constitutional standard and whether District 25 could compensate for the dismantling of Latino opportunity in District 23.

Rule

Mid-decade redistricting is not per se unconstitutional, and a political gerrymandering claim cannot succeed without a reliable standard showing a burden on representational rights; sole partisan motivation alone is insufficient. Under § 2 of the Voting Rights Act, a plaintiff must satisfy the Gingles preconditions and the court must then consider the totality of circumstances, including proportionality. A State may use one majority-minority district to compensate for the absence of another only when both groups would have a § 2 right and both cannot be accommodated; a noncompact district cannot remedy the dismantling of a compact minority opportunity district.

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

After the 2026 elections, the legislature of Franklin replaces a court-drawn congressional map even though no new census has occurred. Emails show the majority party's leaders wanted only to gain seats, but the challengers offer no standard for measuring any burden on representational rights beyond the legislature's partisan purpose.

Under the governing rule, which is the best result on the statewide constitutional challenge?

Explanation. The majority held that there is nothing inherently suspect about a legislature replacing a court-drawn map mid-decade, and that a statewide partisan-gerrymandering claim cannot succeed without a reliable standard showing a burden on representational rights. Proof of partisan purpose alone is insufficient.