## Facts

- Black voters challenged Louisiana’s 1970 state senate reapportionment on grounds of population inequality and racial vote dilution.
- After the U.S. Attorney General objected to the plan under § 5 of the Voting Rights Act, a three-judge federal district court appointed a Special Master to prepare a remedial plan.
- The Special Master conducted hearings over four days, heard from over 100 people, and submitted a proposed map; the district court adopted it after further hearing.
- The contested dispute narrowed to four senate seats in the New Orleans area.
- Louisiana’s Attorney General proposed an alternative map differing only in those four districts; it preserved traditional lines, kept each incumbent in his district, and resulted in four “safe” white districts rather than two districts with slight Black majorities under the Master’s plan.
- The district court found both plans satisfied one-person, one-vote, but selected the Master’s plan based on differences affecting minority voting strength and incumbency.
- The Fifth Circuit summarily reversed without opinion and substituted the state-proposed plan.

## Issues

1. Whether a federal court of appeals may summarily reverse a district court’s detailed reapportionment remedy and substitute a different plan without explaining its reasons, particularly where minority vote dilution concerns are implicated.

## Decision

- The Supreme Court granted certiorari, vacated the Fifth Circuit’s judgment, and remanded.
- The Court held that, absent an explanation for the summary reversal, the court of appeals’ disposition could not stand.
- The Court did not select between the competing reapportionment plans on the merits; it required the Fifth Circuit to provide a reasoned basis if it displaced the district court’s remedy.

## Legal Principles

- When a court of appeals overturns a district court’s carefully developed remedial decree in complex reapportionment and voting-rights litigation, it must provide an articulated rationale sufficient to permit meaningful review.
- Unexplained substitution of an alternative districting plan is improper where the record reflects careful factfinding and competing plans differ materially on matters such as minority voting strength and incumbent effects, even if both satisfy population-equality requirements.

## Conclusion

The Supreme Court required reasoned decisionmaking from the Fifth Circuit before it could displace a district court’s thoroughly vetted reapportionment remedy, vacating the unexplained reversal and remanding for further proceedings with an articulated rationale.


Taylor v. McKeithen, 407 U.S. 191 (1972)