CASE SUMMARY

On February 25, 2014, Georgia's Legislature passed a bill changing the Sumter County Board of Elections and Registration from a nine-member body to a seven-member body, with five members elected from single-member districts under a new redistricting plan and two elected at-large. On March 7, 2014, a resident of Sumter County, Georgia, filed a federal lawsuit against the Sumter County Board of Elections and Registration challenging the new method of election as violating Section 2 of the Voting Rights Act. The plaintiff also alleged that two of the new Board of Education districts violated Section 2 by "packing" black voters into those two districts to dilute their voting strength. He sought a court order requiring the Board of Education to have only nine single-member districts and to institute a new, lawful redistricting plan, and an injunction barring the county from holding their 2014 elections until the new election method was implemented.

On July 14, 2015, the district court granted summary judgment for the defendants, finding that the plaintiff had failed to sufficiently establish the existence of the third Thornburg v. Gingles precondition for Section 2 liability, which requires that the white majority votes sufficiently as a bloc to enable it to usually defeat the minority's preferred candidate. On July 28, 2016, the U.S. Court of Appeals for the Eleventh Circuit reversed the district court's ruling on the grounds the lower court improperly made credibility determinations as to the parties' expert witnesses during the summary judgment stage and remanded the case back to the district court.

On March 17, 2018, the district court ruled that the Board of Education's at-large election scheme for two of its members violated Section 2 of the Voting Rights Act and ordered the defendants to devise a remedial redistricting plan. During the remedial phase, the district court entered an order on August 17, 2018, enjoining the defendants from conducting the November 2018 school board elections on the grounds it wasn't feasible for the court to timely issue a new map with interim boundaries prior to election day. On September 23, 2019, the district court appointed a special master to aid in the creation of a remedial redistricting plan, and on January 29, 2020, the district court adopted the special master's remedial redistricting plan. The defendants appealed all three of these decisions to the U.S. Court of Appeals for the Eleventh Circuit.

On October 27, 2020, the Eleventh Circuit issued its ruling affirming the decisions of the district court, finding no clear errors in its fact-finding or final judgment.

CASE LIBRARY

U.S. District Court for the Middle District of Georgia, Albany Division - No. 1:14-cv-42

U.S. Court of Appeals for the Eleventh Circuit - No. 15-13628

U.S. District Court for the Middle District of Georgia, Albany Division - No. 1:14-cv-42

U.S. Court of Appeals for the Eleventh Circuit - No. 18-11510 [consolidated with Nos. 18-13510 & 20-10394]