In 1991, several groups of Minnesota voters filed different state and federal lawsuits challenging the State's legislative and congressional apportionments under the 14th Amendment of the U.S. Constitution, the Minnesota Constitution, and Section 2 of the Voting Rights Act. The Minnesota Legislature adopted a new legislative districting plan while these cases were pending, but after numerous technical errors in that plan were discovered, the state court issued its own legislative district plan that would become finalized if the Legislature did not act by January 21, 1992. In February 1992, after the state court had adopted their legislative plan and had begun hearings on the parties' submitted congressional plans, the U.S. District Court for the District of Minnesota issued its own legislative and congressional plans and permanently enjoined any interference with the state's implementation of those plans, stating that the state court's legislative plan failed to provide the relief necessary to cure the VRA Section 2 violations it found in certain single-member districts. The State appealed both of the federal District Court's plans to the U.S. Supreme Court, alleging that the District Court erred in not deferring to the state legislature and state courts' ongoing redistricting activities and in finding that there was sufficient evidence of a Section 2 vote dilution claim.
In 1993, the U.S. Supreme Court reversed the District Court's decision and ruled in favor of the appellants on both issues, finding that the federal district court should have deferred to the proceedings at the state level and that the plaintiffs had failed to establish a Section 2 violation. The Court explained that States have the primary duty and responsibility to perform legislative and congressional redistricting, and federal courts must defer their action when a State, through its legislative or judicial branch, has begun to address the issue in a timely fashion. Furthermore, the Court held that the prerequisite conditions announced in Thornburg v. Gingles for bringing a Section 2 claim as to multi-member districts are also necessary to establish a Section 2 claim as to single-member districts, and the plaintiffs had failed to produce such evidence in this case.
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.
U.S. Supreme Court - 507 U.S. 25 (1993)
- Opinion - 2/23/93