Facts
- North Carolina’s General Assembly redrew the Twelfth Congressional District in 1997 after prior litigation invalidated earlier versions of the district as unconstitutional racial gerrymanders.
- North Carolina officials defended the 1997 plan as pursuing a legitimate political objective: creating a reliably Democratic congressional seat.
- Voters challenged the 1997 district under the Equal Protection Clause, alleging that race predominated over traditional districting principles and over politics in drawing the boundaries.
- A three-judge federal district court, after a trial on remand, found that race predominated and held the 1997 district unconstitutional.
- State officials appealed directly to the Supreme Court under 28 U.S.C. § 1253.
Issues
- Whether the record adequately supported the district court’s finding that race, rather than politics, predominated in drawing the 1997 Twelfth District.
- Whether the district court’s factual findings were clearly erroneous given the close correlation between race and party voting in the relevant electorate.
- What evidentiary showing challengers must make to prove that a facially neutral districting plan is “unexplainable on grounds other than race.”
Decision
- The Supreme Court reversed the three-judge district court.
- The Court held that the district court’s finding that race predominated was clearly erroneous on this record.
- The Court concluded that the challenged district lines were explainable by a permissible partisan objective—creating a safe Democratic seat—given evidence tied to voting behavior.
- The Court found the challengers’ proof insufficient to separate race-based line drawing from politics in a setting where race and party affiliation were highly correlated.
Legal Principles
- In a racial-gerrymandering challenge to a facially neutral districting plan, the challengers bear a demanding burden to show the plan is unexplainable on grounds other than race.
- When race and political affiliation are closely correlated, a district’s racial composition and irregular shape do not, standing alone, establish that race predominated over politics.
- Appellate review may deem a trial court’s predominance finding clearly erroneous where the record better supports a partisan explanation and the findings do not adequately distinguish race from politics.
- Evidence of actual voting behavior can be more probative than voter registration in evaluating whether a partisan objective explains districting choices.
- At minimum, challengers must show that the legislature could have achieved its legitimate political objectives through alternative district configurations that are comparably consistent with traditional districting principles.
Conclusion
The Court held that the Equal Protection Clause was not violated because the challengers failed to prove that race, rather than partisan objectives, drove North Carolina’s 1997 configuration of the Twelfth Congressional District, and it reversed the lower court’s contrary finding as clearly erroneous.