Brief Fact Summary.
North Carolina submitted a congressional reapportionment plan creating 2 black-majority districts. One of these districts was, for the most part, no wider than the interstate road along which it stretched, even though it was approximately 160 miles long. Five North Carolina residents challenged the constitutionality of this unusually shaped district.
Synopsis of Rule of Law.
Redistricting based on race must be held to a standard of strict scrutiny under the Equal Protection Clause.
The Equal Protection Clause provides that no State shall deny to any person within its jurisdiction the equal protection of the laws.View Full Point of Law
The U.S. Attorney General rejected a North Carolina congressional reapportionment plan because the plan created only 1 black-majority district. North Carolina submitted a second plan creating 2 black-majority districts. One of these districts was, for the most part, no wider than the interstate road along which it stretched, even though it was approximately 160 miles long.
Five North Carolina residents challenged the constitutionality of this unusually shaped district, alleging that its only purpose was to secure the election of additional black representatives, violating their constitutional right to participate in a “color-blind” electoral process.
Does Plaintiffs’ claim that the state create a racially gerrymandered district raise a valid constitutional issue per the Equal Protection Clause?
Yes, Plaintiffs’ claim that the state create a racially gerrymandered district raises a valid constitutional issue per the Equal Protection Clause.
Although North Carolina’s reapportionment plan was racially neutral on its face, the resulting district shape is so irregular as to evidence a deliberate effort to segregate voters into different districts based on race. Although there may have been good intentions behind creating the unusual district, it seemed to go beyond that which is reasonably necessary to avoid racial imbalances. A reapportionment plan that includes in one district individuals who belong to the same race, but who are otherwise widely separated by geographical and political boundaries, and who may have little in common with one another but the color of their skin, bears an “uncomfortable resemblance to political apartheid.” It reinforces the perception that members of the same racial group – regardless of age, education, economic status, etc. – think alike, share the same political interests, and will prefer the same candidates at the polls. We reject such perceptions as impermissible racial stereotypes.
Plaintiffs’ claim gives rise to an equal protection challenge and this Court remands the case for further proceedings. The district court must decide, based on the evidence presented, whether or not some compelling governmental interest justifies North Carolina’s reapportionment plan.