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Alabama Legislative Black Caucus v. Alabama
United States Supreme Court
575 U.S. 254 (2015)
In 2012, following the 2010 U.S. Census, Alabama (defendant) redrew its electoral districts. Alabama had two primary goals when redistricting: ensuring an equal population of voters within each district according to the one person, one vote principle and complying with the Voting Rights Act (VRA). Section 5 of the VRA required covered jurisdictions—states with a history of racial voter discrimination—to show that any changes made to electoral procedures would not reduce the political power of minority voters. Alabama was a covered jurisdiction. Alabama believed that § 5 required covered jurisdictions to maintain existing percentages of minority voters within majority-minority districts when redistricting. Alabama’s majority-minority districts were underpopulated, so Alabama had to add new individuals to those districts. For example, prior to 2012, District 26 had an approximately 73 percent Black population. Alabama needed to add almost 16,000 people to District 26 for the district to have a population equal to that of other districts. To maintain the percentage of Black voters in District 26, Alabama focused on the race of the district’s potential new members and added only 36 new White individuals. The Alabama Legislative Black Caucus (the caucus) (plaintiff) challenged Alabama’s redistricting, arguing that Alabama violated the VRA and engaged in racial gerrymandering by inappropriately focusing on race when redistricting. The district court held that Alabama did not violate the VRA because race was not the predominant factor in Alabama’s redistricting; rather, Alabama prioritized both race and equal populations. The district court also held that, even if race was the predominant factor, Alabama did not violate the VRA because its redistricting was narrowly tailored to comply with § 5 and, therefore, survived strict scrutiny. To reach its conclusion, the district court adopted Alabama’s belief that § 5 required covered jurisdictions to maintain the existing percentages of minority voters within majority-minority districts. The caucus appealed.
Rule of Law
Holding and Reasoning (Breyer, J.)
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