Taylor v. McKeithen

Background

A group of citizens challenged Louisiana’s 1970 redrawing of state senate districts, saying it violated the one-person, one-vote rule and was designed to dilute Black voting strength. After the U.S. Attorney General objected under Section 5 of the Voting Rights Act, the federal District Court appointed a Special Master, held hearings with over 100 witnesses, and adopted the Master’s plan for four affected New Orleans-area senate seats.

Reasoning

The District Judge found both the Master’s plan and the State Attorney General’s counterplan met equal-population rules, but they differed in racial make-up. The Master’s plan would give Black voters a fair chance in two of the four districts; the State plan kept four “safe” white districts and preserved incumbents’ homes inside their districts. The Court of Appeals reversed without an opinion and adopted the State plan. The Supreme Court granted review, vacated that summary reversal, and sent the case back to the appeals court for a explained decision and further proceedings.

Real world impact

The ruling keeps open federal review of whether judges may adopt district lines that remedy past racial dilution, and it preserves the District Court’s factual findings for reconsideration. The decision is procedural, not a final ruling on which map is lawful; the appeals court must now clarify its reasoning and reassess the competing plans.

Dissents or concurrances

Justice Rehnquist (joined by two colleagues) dissented, arguing that the Supreme Court should not force the appeals court to write an opinion and that lower courts need flexibility to issue short rulings given heavy caseloads.