Allen v. Milligan (2022)
- Docket
- 21-1086
- Decided
- 2022-01-01
- Public Good score
- 88 / 100
- Framers' Intent score
- 35 / 100
Summary
Question: <p>Does Alabama’s 2021 redistricting plan for its seven U.S. House seats violate Section 2 of the Voting Rights Act?</p> Conclusion: <p>The district court correctly applied binding Supreme Court precedent to conclude that Alabama’s redistricting map likely violates Section 2 of the Voting Rights Act. Chief Justice John Roberts authored the majority opinion of the Court.</p> <p>The Court’s decision in <em>Thornburg v. Gingles</em>, 478 U.S. 30 (1986) sets out a three-part framework for evaluating claims brought under Section 2 of the Voting Rights Act. First, the plaintiffs must prove that the minority group is sufficiently large and geographically compact to constitute a majority in a reasonably configured district (measured by criteria such as contiguity and compactness). Second, the plaintiffs must show that the minority group is politically cohesive. Third, the plaintiffs must show that under the totality of the circumstances, the political process is not “equally open” to minority voters.</p> <p>The majority applied that three-part framework to the facts in the record and agreed with the district court that the plaintiffs were likely to succeed on their challenge. The plaintiffs submitted maps demonstrating the traditional districting criteria, and the district court found “no serious dispute” that Black voters are politically cohesive or that the challenged districts’ white majority consistently defeated Black voters’ preferred candidates.</p> <p>Justice Brett Kavanaugh joined the majority opinion except for a discussion of the difference between race-consciousness and race-predominance. He concurred separately to emphasize and clarify four additional points.</p> <p>Justice Clarence Thomas authored a dissenting opinion, in which Justice Neil Gorsuch joined in full, and Justices Amy Coney Barrett and Samuel Alito joined in part. Justice Thomas argued that Section 2 of the VRA does not require Alabama to redraw its congressional districts so that Black voters can control a number of seats proportional to Black voters in its population.</p> <p>Justice Alito authored a dissenting opinion in which Justice Gorsuch joined arguing that the majority’s understanding of <em>Gingles</em>—specifically its understanding of the phrase “reasonably configured” within the context of the first precondition—is flawed, and that a correct understanding would lead to a different result in this case.</p>
Case Brief
Facts
Alabama adopted a 2021 redistricting plan for its seven U.S. House seats, creating two majority-minority districts for Black voters. Plaintiffs, including Black voters and advocacy groups, sued alleging the plan diluted Black voting power in violation of Section 2 of the Voting Rights Act (VRA), arguing Alabama failed to create a second majority-Black district. The district court found the map likely violated the VRA under the three-part *Gingles* framework.
Procedural History
The U.S. District Court for the Middle District of Alabama granted summary judgment for plaintiffs. The Eleventh Circuit Court of Appeals affirmed, and Alabama petitioned the Supreme Court for certiorari, which the Court granted.
Issue
Whether Alabama’s 2021 congressional redistricting plan violates Section 2 of the Voting Rights Act by failing to create a second majority-Black district for Black voters who are politically cohesive and geographically compact.
Holding
Yes. The Court held that the district court correctly concluded Alabama’s redistricting plan likely violates Section 2 of the VRA by failing to create a second reasonably configured majority-Black district where Black voters are sufficiently numerous, politically cohesive, and experience denial of equal access to the political process.
Rule
Section 2 of the VRA prohibits voting practices that result in minority vote dilution. To establish a violation, plaintiffs must prove: (1) the minority group is sufficiently large and geographically compact to form a majority in a reasonably configured district; (2) the minority group is politically cohesive; and (3) the political process is not equally open to the minority group under the totality of circumstances.
Reasoning
The Court applied the *Gingles* framework, finding plaintiffs established all three prongs: Black voters are politically cohesive and form a geographically compact group; Alabama’s map consistently elected white candidates against Black voter preferences; and the map denied Black voters equal opportunity to elect representatives of their choice. The Court rejected Alabama’s claim that its plan satisfied Section 2, emphasizing that Section 2 requires creating districts where minority voters can elect their preferred candidates.
Significance
This case reaffirms the *Gingles* framework as the definitive standard for Section 2 challenges and significantly strengthens protections against minority vote dilution in redistricting, requiring states to create additional majority-minority districts where feasible. It marks a pivotal victory for voting rights advocates in the post-*Shelby County* era and influences future redistricting litigation nationwide.
Public Good Analysis
GPT: The decision strengthens voting rights by protecting minority political participation under the Voting Rights Act, ensuring equitable democratic representation for Black voters and preventing racial vote dilution. This upholds civil liberties and promotes inclusive governance, directly benefiting vulnerable populations and the integrity of democratic processes. | Claude: This decision upholds the Voting Rights Act and protects a fundamental aspect of democratic participation – ensuring minority groups have an equal opportunity to elect representatives of their choice. By affirming the importance of Section 2, the Court safeguards against discriminatory redistricting practices that could disenfranchise Black voters and undermine representative governance.
Framers' Intent Analysis
GPT: The original constitutional framers (1787) intended state sovereignty over voting qualifications and explicitly excluded Black citizens from citizenship and suffrage (e.g., the Three-Fifths Compromise). They would not have supported federal judicial mandates for majority-minority districts, as this contradicts their foundational intent to limit federal power in electoral matters and preserve state control over voting rules. | Claude: While the Framers valued representative government, this ruling relies heavily on statutory interpretation of post-Civil War legislation (VRA) and departs from a strictly textualist approach. James Madison, advocating for a large republic in *Federalist No. 10*, prioritized preventing tyranny of factions; while redistricting addresses representation, it does so through expansive federal power over state election laws – something many originalists would view with skepticism, as the Framers intended limited federal intervention in such matters.