Opinion: 581 U.S. 285 (2017)
HOLDING: The Equal Protection Clause of the Fourteenth Amendment limits racial gerrymanders in legislative districting plans, which are justified only if the State proves that its race-based sorting of voters serves a compelling interest and is narrowly tailored to that end. The District Court’s findings of an unconstitutional gerrymander were upheld because its factual determination that the redrawing of two congressional districts was predominately based on race was entitled to deference and there was no evidence of a good reason to justify using race as the predominant factor in the redistricting decision. A contrary result reached by a state court did not have preclusive effect because the lawsuits involved different plaintiffs.
After the 2010 census, the North Carolina General Assembly needed to redraw several state congressional districts in accordance with the one-person-one-vote principle. State Senator Robert Rucho and State Representative David Lewis, on behalf of the legislative committees responsible for preparing the revamped map, hired Dr. Thomas Hofeller, a political mapmaker, to redraw North Carolina’s district lines. Included in the redistricting plans were significant alterations to two districts, District 1 and District 12.
The census showed that District 1 was substantially underpopulated, needing nearly 100,00 new people within the district’s boundaries. Rucho, Lewis, and Hofeller redrew the district to include a finger-like extension which encompassed areas of Durham with a heavy proportion of black voters. And while District 12 needed no significant population changes, its district was redrawn to extend into parts of Guilford County, gaining 35,000 black voters and losing 50,000 white voters. In both redrawn districts, over half the voters were black, creating majority-minority districts and diluting black votes throughout other districts. The legislature adopted these maps.
Registered voters from these two districts bought a suit against North Carolina officials, alleging that the districts were impermissibly gerrymandered based on race. The District Court convened a three-judge panel to conduct the trial and determined that both districts were unconstitutional. North Carolina appealed.
The Supreme Court affirmed. For District 1, the evidence that North Carolina had purposefully established a racial target for the district was uncontested and explicit, and this was already a district where candidates supported by the black voting bloc won consistently. This race-based map-drawing did not survive strict scrutiny because there was no evidence to support the State’s proffered reason – compliance with the Voting Rights Act.
For District 12, the record supported the trial court’s factual finding that North Carolina had purposefully redrawn the district for racial reasons. North Carolina officials claimed that District 12 was redrawn only for political reasons to make the state’s district map “more favorable to Republican candidates.” But these officials made contradictory statements on this point, including evidence that Rucho and Lewis told Hofeller not to use race when designing District 12, “except perhaps with regard to Guilford County.” This factual finding was entitled to deference, and the State otherwise made no showing that such race-based map-drawing was necessary. Since North Carolina made no attempt to justify the race-based redistricting, the redesign was unconstitutional.
Finally, the Court held that the fact that the State had prevailed on the same issues in state court did not preclude this lawsuit or this result. The plaintiffs were not the same and the trial court found there was no special relationship between the plaintiffs in the two cases such that the state court judgment bound the federal plaintiffs. One person’s lawsuit generally does not bar another’s, no matter how similar they are in substance.
Source: Supreme Court Opinion Appendix