Case Summary

After North Carolina’s congressional redistricting plan was denied preclearance under § 5 of the federal Voting Rights Act (“VRA”), the State revised its plan to include a second majority-Black district that was very oddly shaped, stretching for 160 miles along an interstate. Soon after, five North Carolina voters filed a federal lawsuit against various state and federal officials challenging the two majority-Black districts as unconstitutional racial gerrymanders, claiming the State ignored traditional redistricting criteria and drew lines solely based on race.

  • The U.S. District Court for the Eastern District of North Carolina dismissed the suit for the failure to state a claim, finding that favoring minority voters was not constitutionally discriminatory and the plan as a whole did not cause proportional underrepresentation for white voters statewide. Plaintiffs then appealed to the U.S. Supreme Court.
  • On June 28, 1993, SCOTUS reversed and conclusively held that plaintiffs can state a racial gerrymandering claim under the 14th Amendment by alleging that a redistricting scheme is “so irrational on its face that it can only be understood as an effort to segregate voters into separate districts on the basis of race, and that the separation lacks sufficient justification.” It explained racial gerrymandering threatens different harms than those in vote dilution claims and, therefore, any state laws that explicitly distinguishes among citizens based on their race must be narrowly tailored to further a compelling governmental interest. The Court rejected the argument that racial gerrymandering doesn’t implicate constitutional concerns when it favors the minority group, noting that the equal protection analysis doesn’t depend on the race of those benefitted or burdened by the classification, but ultimately declined to rule as to whether the intentional creation of a majority-minority district would always give rise to an equal protection claim.

Significance: Showing that an otherwise racially neutral redistricting plan produces a district which is so bizarrely shaped that it can only be rationally explained as an effort to segregate voters on the basis of race without adequate justification is sufficient to state a claim under the 14th Amendment's Equal Protection Clause.

Case Library

U.S. Supreme Court - 509 U.S. 630 (1993)