After the Florida legislature adopted a legislative reapportionment plan in 1992, several different federal lawsuits were filed by a group of Hispanic voters, a group of African American voters, and the federal government, all alleging that the plan cracked cohesive minority populations across the state and diluted their votes in violation of Section 2 of the Voting Rights Act. The plaintiffs' claims centered around several areas throughout the state where they argued black or Hispanic populations could have formed a voting majority in a politically cohesive, reasonably compact district (or in more than one). The defendant-state officials defended their plan on the grounds that the districts as drawn permitted the state's minority groups to elect candidates of their choice in a number of districts that was roughly proportional to their respective statewide populations, and this bars the plaintiffs' claims of vote dilution. The U.S. District Court for the Northern District of Florida consolidated the three cases and, following a trial, found that the Thornburg v. Gingles preconditions were established, that Hispanic and African American populations in Florida had suffered historically from official discrimination and continued to feel those effects, and that the state could and should have devised a plan containing more majority-minority House and Senate districts. Based on those findings alone, the district court held that the state's legislative reapportionment plan violated Section 2.
In 1994, the U.S. Supreme Court reversed the District Court's ruling on the grounds that the lower court's decision was based upon an erroneous application of the Gingles preconditions and totality of circumstances analysis under Section 2. The Court stated that although the Gingles preconditions are necessary to state a claim of vote dilution under Section 2, they are not necessarily sufficient. Rather, the court must assess the significance of the Gingles factors after considering all past and present circumstances relevant to determining whether the political process is equally open to minority populations under the challenged plan, which the district court failed to do here. While the Court rejected the state officials' argument that proportionality of minority voting strength to their statewide population was a dispositive bar to vote dilution claims under Section 2, the Court did recognize that proportionality is a relevant factor to consider in the totality of circumstances analysis because it is an indication that minority voters have equal electoral opportunities in spite of racial polarization. In light of its proportionality between minority populations and their voting strengths, as well as the plaintiffs' failure to produce evidence otherwise indicating that minority voters have less of an opportunity to elect representatives of their choice under it, the Court held that Florida's legislative reapportionment plan did not violate Section 2.
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.
U.S. Supreme Court - 512 U.S. 997 (1994)
- Opinion - 6/30/94