Alabama Legislative Black Caucus v. Alabama (2014)
- Docket
- 13-895
- Decided
- 2014-01-01
Summary
Question: Did the district court apply the correct law when evaluating whether Alabama’s 2012 redistricting violated the Equal Protection Clause of the Fourteenth Amendment and the Voting Rights Act of 1965? Conclusion: No. Justice Breyer delivered the opinion for the 5-4 majority. The Court held that the district court improperly considered evidence of statewide racial effects as a claim that the state used race as a factor when redrawing all of the boundary lines, when the actual allegations were that the racial gerrymandering took place in a few select electoral districts. Next, the Court held that the evidence suggested that the Caucus had standing to sue because it appeared to have members in every electoral district in the State of Alabama; the Court directed the Caucus to provide membership information sufficient to support this inference on remand. The district court also erred by considering Alabama’s goal of obtaining a 1% population deviation among districts as a relevant factor to determine whether race was a “predominate” factor in redrawing the electoral districts rather than considering the traditional goals of the Voting Rights Act. Finally, the Court rejected the district court’s holding that Alabama’s gerrymandering satisfied strict scrutiny. In application, Alabama’s interest in maintaining a particular population percentage of minority voters in each district did not equate to the Voting Rights Act’s goal of preventing “retrogression in respect to racial minorities’ ‘ability . . . to elect their preferred candidates of choice’; therefore, using a race as a factor to meet Alabama’s extraneous goals was not justified. The Court vacated and remanded the district court’s decision for further consideration consistent with its holding and additional evidence. Justice Antonin M. Scalia authored a dissenting opinion in which he argued that the majority decision reached beyond the record because the Caucus’ complaint failed to adequately address the issues of standing and whether the allegations were a statewide claim or a select electoral district claim. Chief Justice John G. Roberts, Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent. Justice Thomas also wrote a separate dissenting opinion in which he argued that the Court’s quest to obtain “the best racial quota” was an ill-begotten one, and that Alabama’s task of complying with the convoluted goals of the Voting Rights Act was nearly impossible given all of the competing laws, jurisprudence, policies, and procedures.