Case Summary

In 1992, several different federal lawsuits were filed and consolidated challenging the Florida Legislature’s newly adopted legislative redistricting plan as diluting Black and Hispanic voters’ voting strength in violation of § 2 of the Voting Rights Act (“VRA”), citing several areas throughout the state where minority populations could’ve formed a politically cohesive, reasonably compact district that wasn’t drawn. Defendant state-officials argued the plaintiffs could not establish a § 2 vote dilution claim because the number of districts drawn in which the state’s minority groups were able to elect candidates of their choice was roughly proportional to their respective statewide populations.

  • The federal district court held the plan violated § 2 because the Thornburg v. Gingles preconditions were established, Florida’s minority populations had suffered historically from official discrimination and continued to feel those effects, and the state could have drawn a plan containing more majority-minority legislative districts. Defendants appealed to the U.S. Supreme Court.
  • On June 30, 1994, SCOTUS reversed and upheld the plan as lawful, citing the district court’s erroneous application of the Gingles analysis. The Court stated the three Gingles factors’ existence are necessary to establish a § 2 violation but not necessarily sufficient on their own; instead, their significance must be assessed only after considering all past and present circumstances relevant to whether the political process is equally open to minority populations under the challenged plan, which the district court failed to do here. The Court also explained that proportionality of minority voting strength to statewide population is not a total bar to vote dilution claims, but it is a relevant factor to consider in the totality of circumstances since it can indicate equal electoral opportunities for minority populations despite racial polarization.

Significance: When analyzing a Section 2 vote dilution claim, the fact that minority representation under the plan is roughly proportional to minority population statewide, although relevant, is not entirely dispositive.

Case Library

U.S. Supreme Court - 512 U.S. 997 (1994)