Case Summary

When Alabama redrew its legislative districts in 2012, it prioritized two goals: keeping all districts’ population deviations to less than 1% from ideal and maintaining approximately the same black populations in existing majority-minority districts to avoid retrogression under § 5 of the federal Voting Rights Act (“VRA”). On August 10, 2012, the Alabama Legislative Black Caucus and others filed a federal lawsuit challenging Alabama’s 2012 legislative redistricting plans as an unconstitutional racial gerrymander in violation of the 14th Amendment’s Equal Protection Clause.

  • In December 2013, the federal district court upheld the plans as constitutional. Analyzing the plaintiffs’ racial gerrymandering claim as referring to the State “as a whole, rather than district-by-district,” the court found that equal population was the predominant factor when drawing the plans, not race. The plaintiffs appealed to the U.S. Supreme Court.
  • On March 15, 2015, SCOTUS reversed the district court’s decision on two separate grounds. First, the lower court erred by not analyzing the plaintiffs’ racial gerrymandering claim on a district-by-district basis. Second, it erred in finding that equal population, not race, predominated when drawing district lines because equal population is a baseline requirement when redistricting, not a traditional redistricting consideration, and can thus never be classified as the “predominant” consideration.

Significance: (1) Racial gerrymandering claims must be assessed on a district-by-district basis, not by examining the state's plan as a whole, and (2) equal population is not a traditional redistricting consideration but rather is a baseline requirement, and therefore it can never classified as the "primary" consideration when drawing lines.

Case Library

U.S. District Court for the Middle District of Alabama, Northern Division - 2:12-cv-00691

U.S. Supreme Court - 13-895 [135 S.Ct. 1257 (2015)]