## Facts

- Alabama enacted 2012 redistricting plans for its state House (105 districts) and Senate (35 districts) while subject to Voting Rights Act § 5 preclearance.
- The legislature pursued two stated goals: (1) population equality within ±1% of ideal and (2) avoiding § 5 “retrogression” by keeping roughly the same Black population percentages in existing majority-minority districts.
- The Alabama Legislative Black Caucus and the Alabama Democratic Conference alleged the plans used race as the predominant line-drawing factor, packing Black voters into majority-minority districts and weakening Black electoral influence elsewhere, in violation of equal protection.
- A three-judge federal district court largely treated the lawsuit as a statewide challenge to the plans (with the Conference also challenging four Senate districts) and upheld the plans, finding race did not predominate; alternatively, it held the plans satisfied strict scrutiny as narrowly tailored to avoid § 5 retrogression.
- The Supreme Court vacated and remanded.

## Issues

1. Whether the organizational plaintiffs had standing to bring racial gerrymandering claims.
2. Whether a racial gerrymandering claim may be resolved by evaluating a statewide plan as a whole, rather than district-by-district.
3. Whether the district court applied the correct predominance test, including its treatment of Alabama’s population-equality objective.
4. Whether Alabama and the district court misinterpreted Voting Rights Act § 5 by treating non-retrogression as requiring maintenance of specific minority-percentage targets.

## Decision

- The Court vacated the judgment and remanded for further proceedings.
- The Court held racial gerrymandering must be analyzed district-by-district; statewide evidence may inform the inquiry but cannot replace district-specific findings.
- The Court held the Conference had standing to challenge the four Senate districts where its members resided and directed that the Caucus be permitted on remand to prove member residency across the challenged districts.
- The Court rejected the district court’s approach that weighed a ±1% population-equality target against race in the predominance inquiry, explaining population equality is a baseline constraint, not a traditional districting criterion that offsets racial sorting.
- The Court rejected a mechanical § 5 theory requiring preservation of the same minority percentages in majority-minority districts, emphasizing § 5 focuses on maintaining minorities’ ability to elect preferred candidates.

## Legal Principles

- A Shaw/Miller racial gerrymandering claim is district-specific because the alleged injury is the placement of voters into districts based primarily on race.
- Race predominates when it overrides traditional districting criteria (e.g., compactness, contiguity, and respect for political subdivisions) in deciding who is included in or excluded from a particular district.
- Population equality is a constitutional requirement that operates as a constraint; it is not weighed as a competing traditional criterion in deciding whether race predominated.
- Voting Rights Act § 5 non-retrogression concerns minority voters’ ability to elect candidates of choice, not preservation of any fixed numerical minority percentage.
- A strict-scrutiny justification premised on an incorrect understanding of § 5 cannot establish narrow tailoring.

## Conclusion

The Supreme Court required a district-by-district assessment of whether race predominated in Alabama’s 2012 legislative redistricting and clarified that § 5 does not demand maintenance of specific minority-percentage levels, vacating and remanding for reconsideration under the correct standards.


Alabama Legislative Black Caucus v. Alabama, 575 U.S. 254 (2015)