CASE SUMMARY

In 1985, two federal lawsuits were filed challenging the use of at-large elections for Liberty County, Florida’s School Board and County Commission as diluting Black voting strength in violation of Section 2 of the Voting Rights Act (“VRA”) and the 14th and 15th Amendments to the U.S. Constitution. They sought an injunction barring the at-large election schemes from use in future elections, an order dividing the county into five single-member districts, including one majority-Black district.

  • The federal district court consolidated the two cases for trial and rejected the plaintiffs’ claims for failure to produce sufficient evidence of a VRA violation. Plaintiffs appealed to the U.S. Court of Appeals for the Eleventh Circuit.
  • On December 12, 1988, an Eleventh Circuit panel vacated the district court’s decision citing several errors in their conclusions of fact and in its application of the Thornburg v. Gingles analysis for VRA § 2 vote dilution claims. The Eleventh Circuit soon after granted a petition to rehear the case en banc.
  • On April 26, 1989, the en banc Eleventh Circuit vacated the panel’s prior opinion and held, as a matter of law, plaintiffs had established the existence of the three Gingles factors but the court was divided on how the Gingles factors should be interpreted and utilized for a § 2 vote dilution claim. In light of its split opinions, the en banc court remanded the case back to the district court with instructions to procced in accordance with the Gingles framework and the views expressed in its concurring opinions.
    • Judge Kravitz’s concurrence stated the Gingles factors were necessary to establish and, in some cases included this one, prevail on a § 2 claim.
    • Judge Tjoflat’s concurrence stated the totality of circumstances test being included in the framework meant a defendant could still rebut a § 2 claim even after a plaintiff had offered proof of the Gingles factors, specifically noting a showing that the community in question wasn’t motivated by racial bias in its voting would bar the establishment of a vote dilution claim.
  • On March 31, 1997, the district court on remand again held the plaintiffs failed to establish a § 2 violation and the plaintiffs again appealed to the Eleventh Circuit.
  • On February 3, 1999, an Eleventh Circuit panel reversed and held both the County School Board and County Commission at-large election schemes violated VRA § 2, citing clear error in the district court’s findings. On March 14, 2000, the Eleventh Circuit granted a petition to rehear the case en banc and vacated the panel’s decision.
  • On August 10, 2000, the en banc Eleventh Circuit affirmed the district court’s decision rejecting the plaintiffs’ claims, finding the lower court properly understood and applied the law and correctly concluded Black voters had equal access to the political process and an equal opportunity to elect representatives of their choice.

CASE LIBRARY

U.S. Court of Appeals for the Eleventh Circuit - Nos. 87-3406 & 87-3406A

U.S. District Court for the Northern District of Florida, Tallahassee Division - Nos. TCA 85-7009 & TCA 85-7010

  • Opinion [957 F.Supp. 1522] - 3/31/97

U.S. Court of Appeals for the Eleventh Circuit - No. 97-2540