Hunt v. Cromartie

1999-05-17

Headline: Court reverses lower court and blocks summary ruling that North Carolina’s oddly shaped 12th District was an illegal racial gerrymander, sending the dispute back for trial to test race versus politics.

Holding: The Court reversed the district court’s summary judgment that North Carolina’s 12th Congressional District was an unconstitutional racial gerrymander, holding that disputed evidence of legislative motive required further fact-finding rather than immediate judgment.

Real World Impact:

Sends disputed redistricting case back for trial and fact-finding.
Requires courts to resolve whether race or politics predominated before ruling.
Leaves North Carolina’s 1998 plan in place while the motive is determined.

Topics: racial gerrymandering, congressional redistricting, voting rights, political gerrymandering

Summary

Background

North Carolina state officials drew a new 1997 congressional map that altered the long, snakelike 12th District. People who challenged the map said it unlawfully sorted voters by race and sued to block elections under the 1997 plan. A three-judge District Court granted the challengers summary judgment and an injunction before discovery or an evidentiary hearing, finding the district collected precincts by racial identification rather than political identification. The State appealed.

Reasoning

The Supreme Court addressed whether race was the primary reason the legislature drew the district. The Court explained that when a law is race-neutral on its face, courts must probe whether race predominated in the lawmakers’ motives. The challengers offered maps, compactness scores, and boundary comparisons; the State responded with affidavits from two legislators and an expert, Dr. David W. Peterson, who argued the lines fit a partisan (Democratic) explanation because race and party were highly correlated. Because the parties’ evidence supported competing reasonable inferences about motive, the Court held summary judgment for the challengers was inappropriate and reversed the injunction.

Real world impact

The ruling sends the case back for further fact-finding or trial to determine whether race or partisan politics dominated the redistricting decision. The Court left open the possibility that, after a full record, race might be found predominant. The opinion also notes North Carolina adopted a 1998 map for elections and that the State would revert to the 1997 map if the State ultimately prevails.

Dissents or concurrances

Justice Stevens, joined by three colleagues, concurred in the judgment and emphasized that an odd district shape can reflect political motives and that registration does not always predict actual votes in North Carolina.