Case Summary

In 1991, several different groups of Minnesota voters filed federal and state lawsuits challenging the state’s congressional and legislative redistricting plans as violating the U.S. and Minnesota Constitutions as well as § 2 of the federal Voting Rights Act. While these cases were pending, the state legislature adopted a new legislative redistricting plan but after numerous technical errors were discovered in that plan, the state court issued its own legislative redistricting plan that would become final if the legislature failed to act by January 21, 1992.

  • In February 1992, after the state court had adopted its own legislative plan and had begun hearings on proposed congressional plans, the federal district court in Minnesota found the state court’s legislative plans failed to remedy certain VRA § 2 issues, ordered its own congressional and legislative plans be adopted, and permanently enjoined any interference with their implementation. State defendants appealed both of the federal court’s plans to the U.S. Supreme Court.
  • On February 23, 1993, SCOTUS reversed the federal district court’s decision, finding it should have deferred to the ongoing proceedings at the state level and that the plaintiffs had also failed to establish a § 2 violation. The Court, noting that states have the primary duty and responsibility to perform congressional and legislative redistricting, held that federal courts must defer their action when a State, through either its legislative or judicial branch, had begun to address the issue in a timely fashion. Additionally, the Court held that the Thornburg v. Gingles preconditions for bringing a § 2 vote dilution claim against multi-member districts were also required for § 2 vote dilution claims against single-member districts, and plaintiffs failed to show them here.

Significance: (1) When redistricting actions are taking place simultaneously at the federal and state levels, federal courts must defer to the state level entities' proceedings because the States have the primary authority to conduct redistricting; (2) the Thornburg v. Gingles preconditions must also be established when bringing a Section 2 vote dilution claim against single-member electoral districts.

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U.S. Supreme Court - 507 U.S. 25 (1993)