North Carolina State Conference of the NAACP v. McCrory
United States Court of Appeals for the Fourth Circuit
831 F.3d 204 (2016)
- Written by Jamie Milne, JD
Facts
Voting in North Carolina was racially polarized, with Black residents favoring the Democratic Party and White residents favoring the Republican Party. Although North Carolina had a history of racially discriminatory voting practices, recent expansions of voting access meant that by 2013, Black voter registration and turnout was nearly equal with White registration and turnout. With the Republican Party having recently gained control of the state’s legislature, legislation was proposed that would restrict voting and registration by tightening restrictions on accepted photo IDs for in-person voting, reducing the early-voting period, eliminating same-day registration at early voting, eliminating out-of-precinct voting, and eliminating the preregistration of youth approaching voting age. When evaluating the proposal, the legislature asked for and reviewed data regarding the use of voting practices by race. The data showed that the voting practices to be restricted were relied on disproportionately by Black voters. Nevertheless, the legislature enacted the proposed election laws, stating that they were intended to achieve legitimate state interests, such as reducing election fraud. The North Carolina State Conference of the National Association for the Advancement of Colored People (conference) and others (plaintiffs) sued North Carolina’s governor, Patrick McCrory, and others (defendants), challenging the new laws on multiple grounds, including violation of the Fourteenth Amendment’s Equal Protection Clause. The district court concluded that the laws were not motivated by discriminatory intent and therefore upheld them as constitutional. The conference and other challengers appealed.
Rule of Law
Issue
Holding and Reasoning (Motz, J.)
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