Miller v. Johnson
United States Supreme Court
515 U.S. 900, 115 S. Ct. 2475, 132 L. Ed. 2d 762 (1995)
- Written by Jamie Milne, JD
Facts
From 1980 to 1990, the State of Georgia had 10 congressional districts. The 1990 census revealed that Georgia’s population entitled it to an eleventh seat, requiring creation of an eleventh district. Georgia’s legislature developed a redistricting plan and submitted it to the Justice Department for preclearance as required by the Voting Rights Act to ensure that proposed changes would not negatively impact racial minorities. The proposed plan would have increased Georgia’s majority-minority districts, meaning districts predominated by minority voters, from one to two. The attorney general denied preclearance. Georgia’s legislature submitted a second plan, but it too was denied preclearance. It became clear that the Justice Department preferred a plan proposed by the American Civil Liberties Union that would create a third majority-Black district. The Georgia legislature then designed a redistricting plan in line with that plan. To create a third majority-minority district, the legislature drew the eleventh district in a way that stretched from Atlanta to Savannah. It encompassed four separate and distinct cities linked by hundreds of miles of narrow rural corridors. The Justice Department approved the plan. In the 1994 elections, all three majority-minority districts elected Black candidates. Five White voters living in the eleventh district (plaintiffs) filed suit against various state officials (defendants), alleging that the eleventh district was a racial gerrymander, meaning a manipulation of electoral boundaries for racial purposes, and therefore violated the Fourteenth Amendment’s Equal Protection Clause. The district court held in the voters’ favor, and the state officials appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
Concurrence (O’Connor, J.)
Dissent (Stevens, J.)
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