Facts
- North Carolina enacted a 1982 legislative redistricting plan using one single-member district and several multimember districts for state legislative elections.
- Black registered voters challenged one single-member district and six multimember districts, alleging the plan diluted Black voting strength and impaired their ability to elect candidates of choice.
- While the case was pending, Congress amended § 2 of the Voting Rights Act (1982) to permit liability based on discriminatory results, not discriminatory intent.
- The federal district court applied amended § 2 and, under the totality of circumstances, found vote dilution in the challenged districts.
- State officials appealed directly to the U.S. Supreme Court as to five multimember districts.
Issues
- What plaintiffs must prove to establish that multimember districts violate § 2 of the Voting Rights Act by diluting minority voting strength.
- How amended § 2’s results test applies to claims that multimember elections submerge minority voters and reduce their opportunity to elect preferred candidates.
Decision
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The Supreme Court affirmed in part and reversed in part, and adopted a district-specific framework for § 2 vote-dilution claims.
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The Court held that plaintiffs must prove three preconditions to establish vote dilution in multimember districts:
- the minority group is sufficiently large and geographically compact to form a majority in a hypothetical single-member district,
- the minority group is politically cohesive, and
- the majority votes sufficiently as a bloc to usually defeat the minority’s preferred candidates.
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If the preconditions are met, the court then evaluates liability under the totality of circumstances.
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Applying this framework, the Court upheld findings of unlawful vote dilution in most of the contested districts but rejected the determination as to one district for insufficient proof under the required elements.
Legal Principles
- Section 2 (as amended in 1982) imposes a results standard: plaintiffs need not prove discriminatory purpose if the challenged electoral structure results in minority voters having less opportunity to participate and to elect representatives of their choice.
- A § 2 vote-dilution claim challenging multimember districts generally requires proof of the three “Gingles preconditions” (size/compactness, minority political cohesion, and usual defeat by majority bloc voting).
- Racially polarized voting may be shown through election data demonstrating cohesive minority voting and majority bloc voting sufficient to usually defeat minority-preferred candidates; § 2 does not require proof that race is the sole cause of voting patterns.
- The statute does not create a right to proportional representation; proportionality and the extent of minority electoral success are relevant, but not dispositive, within the totality-of-circumstances inquiry.
Conclusion
The Court interpreted amended § 2 to reach vote dilution based on discriminatory results and established a three-part, district-specific threshold showing for such claims, then requiring a totality-of-circumstances assessment to determine whether electoral structures unlawfully impair minority voters’ opportunity to elect preferred candidates.