## Facts

- Black registered voters in Orleans Parish and a voting-rights organization challenged Louisiana’s method of electing two justices from the Louisiana Supreme Court’s First Supreme Court District, alleging minority vote dilution under § 2 of the Voting Rights Act and violations of the Fourteenth and Fifteenth Amendments.
- The district court initially dismissed the action, concluding § 2 did not cover judicial elections and that the constitutional claims lacked allegations of discriminatory intent.
- On a prior appeal, the Fifth Circuit reversed, holding § 2 applies to judicial elections and reinstating the statutory and constitutional claims.
- On remand, with an election scheduled for October 1, 1988 for the seat held by an incumbent justice, plaintiffs sought a preliminary injunction to stop the election under the challenged structure pending resolution on the merits.
- The district court granted the preliminary injunction enjoining the election; state officials appealed in an interlocutory appeal.

## Issues

1. Whether the district court abused its discretion by preliminarily enjoining a scheduled Louisiana Supreme Court election while the § 2 vote-dilution claim remained unresolved.

## Decision

- The Fifth Circuit vacated the preliminary injunction and ordered the election to proceed under Louisiana law.
- The court held that the extraordinary remedy of stopping a state election was not justified on the preliminary-injunction record and timing.
- The court emphasized the public-interest harms and institutional disruption that would likely follow from halting a state supreme court election close to the election date.
- The court did not decide the merits of the § 2 or constitutional claims.

## Legal Principles

- Preliminary injunctions require a strong showing under the traditional four-factor test, and appellate review is for abuse of discretion.
- Federal courts should be highly reluctant to disrupt state election processes, particularly when relief is sought near the election date.
- In assessing preliminary relief affecting elections, courts weigh public interest and institutional stability, including risks of confusion, uncertainty, and impairment of governmental functions.
- If an election system is later found unlawful, the state legislature ordinarily should have the first opportunity to enact a corrective remedy before a federal court imposes one.

## Conclusion

The Fifth Circuit concluded that enjoining the imminent election for a seat on the Louisiana Supreme Court posed substantial public-interest and institutional risks and that those considerations, together with the interlocutory posture, made preliminary relief improper; the underlying Voting Rights Act and constitutional claims remained for later merits adjudication.


Chisom v. Roemer, 853 F.2d 1186 (5th Cir. 1988)