Case Summary

Plaintiffs filed a lawsuit in Louisiana state court against various elected state officials challenging the state's congressional redistricting plan as an unconstitutional racial gerrymander in violation of the 14th Amendment's Equal Protection Clause. The plaintiffs were all residents of Louisiana's 5th Congressional District, however their lawsuit was challenging the constitutionality of Louisiana's 4th Congressional District. After the State removed the case to the U.S. District Court for the Western District of Louisiana, the District Court invalidated the congressional map as unconstitutional and substituted its own districting plan. The State appealed the District Court's ruling to the U.S. Supreme Court, arguing that the plaintiffs lacked standing to challenge a district of which they were not residents.

In 1995, the U.S. Supreme Court ruled in favor of the State, finding that the plaintiffs had not suffered the injury that Article III standing requires. The Court explained that because the plaintiffs were all residents of the 5th Congressional District, and their claim alleged that the 4th Congressional District was racially gerrymandered, the plaintiffs could not demonstrate that they, personally, had been subjected to a racial classification so as to create a cognizable, actionable injury. In the absence of any such injury, the plaintiffs did not have standing to bring this lawsuit and so, the Court remanded the case with instructions to dismiss the complaint.

Significance: In order to have standing to bring a racial gerrymandering claim, a plaintiff must be a resident of the district being challenged.

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U.S. Supreme Court - 515 U.S. 737 (1995)