Alabama Legislative Black Caucus v. Alabama

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Election Law
  • Date Filed: March 25, 2015
  • Case #: 13-895
  • Judge(s)/Court Below: Breyer , J., delivered the opinion of the Court, in which Kennedy, Ginsburg, Sotomayor, and Kagan, JJ., joined. Scalia , J., filed a dissenting opinion, in which Roberts, C.J., and Thomas and Alito, JJ., joined. Thomas , J., filed a dissenting opinion.
  • Full Text Opinion

The redistribution of majority-minority voters into fewer districts is unconstitutional when it decreases the overall strength of voters within the state.

The petitioners argued the legislature intentionally packed a greater numbers of minority voters into fewer districts, thereby increasing their margin of victory in those districts while decreasing the overall strength of the voters within the state. When the legislature redrew the state’s legislative maps in 2011, it adopted a policy requiring the population of majority-minority districts to be kept at pre-redistricting levels, even if that meant certain districts had to be significantly reshaped in order to equalize population under the guise of avoiding violating Section 5 of the Voting Rights Act.

The Supreme Court vacated, remanded and held that the lower court applied the incorrect legal standards in evaluating the redistricting of the voting boundaries. The lower courts looked at four different determinations: the geographical nature of racial gerrymandering; standing; racial predominance; and narrow tailoring/compelling state interest. Each of the determinations reflected an error about relevant law applicable to the defense, which resulted in a flaw of the lower court's decision, in particular that the Voting Rights Act cannot be used to justify maps that group voters together based primarily on their race.

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