## Facts

- After the 2000 census, Texas gained two congressional seats, but the state legislature failed to enact a new map.
- A three-judge federal court imposed a congressional plan using neutral criteria (e.g., respecting political subdivisions and avoiding incumbent pairings).
- In 2003, after partisan control of the Texas Legislature changed, the Legislature enacted a new congressional map (Plan 1374C) using the same census data, aiming to change the partisan composition of the delegation.
- Minority-rights organizations, individual voters, and local entities challenged the plan, alleging unconstitutional mid-decade redistricting, unconstitutional partisan gerrymandering, and minority vote dilution under § 2 of the Voting Rights Act (VRA).
- A three-judge federal district court upheld the plan; challengers appealed to the U.S. Supreme Court.

## Issues

1. Whether a state violates the Constitution by redistricting congressional seats mid-decade using the most recent decennial census data.
2. Whether Texas’s 2003 plan was invalid as an unconstitutional partisan gerrymander.
3. Whether the reconfiguration of Congressional District 23 unlawfully diluted Latino voting strength in violation of VRA § 2.
4. Whether challenges to other districts (including Dallas–Fort Worth area districts such as District 24) established vote dilution or other constitutional/statutory violations.

## Decision

- The Court affirmed in part, reversed in part, vacated in part, and remanded.
- Mid-decade redistricting was not per se unconstitutional; the Constitution does not require redistricting only once per decade if population equality and other constraints are satisfied.
- The Court declined to invalidate the statewide plan based on partisan gerrymandering; no controlling, workable standard was applied to strike the plan on that theory.
- District 23 violated VRA § 2 because the 2003 changes diluted Latino voters’ opportunity to elect their candidate of choice by moving cohesive Latino communities out of the district and increasing Anglo voting strength.
- Challenges to other districts, including District 24, were rejected; plaintiffs did not establish the prerequisites for § 2 liability or a legally cognizable dilution theory on the record presented.
- The case was remanded for a remedial map addressing the District 23 violation and related necessary adjustments.

## Legal Principles

- States may enact mid-decade congressional redistricting; frequency alone is not a constitutional defect absent violation of population equality or other constitutional limits.
- Partisan gerrymandering claims were not resolved by a single controlling standard in this decision; the Court did not grant statewide relief based on partisan intent and effects.
- VRA § 2 vote-dilution claims in redistricting require application of the *Gingles* preconditions and a totality-of-circumstances inquiry, with an intensely local, district-specific assessment.
- A state may not deliberately reconfigure a district to strip a cohesive minority community of an emerging and realistic electoral opportunity; statewide proportionality does not automatically cure a specific district-level denial of equal electoral opportunity.
- VRA § 2 does not require maximizing minority voting strength or preserving minority “influence” districts absent satisfaction of the statutory prerequisites for an effective opportunity district.

## Conclusion

The Court held that Texas could redraw congressional districts mid-decade and refused to overturn the plan statewide on partisan-gerrymandering grounds, but it found that the redesign of District 23 unlawfully diluted Latino voting power under VRA § 2 and required a targeted remedial redistricting.


League of United Latin Am. Citizens v. Perry, 548 U.S. 399 (2006)