Dallas County v. Reese
Headline: Ruling lets countywide voting with residency-based candidate districts stand, reversing appeals court and requiring actual proof of vote dilution before invalidating such county election systems affecting Selma residents.
Holding: The Court reversed the appeals court, holding that countywide-elected officials who must live in residency districts represent the whole county, and the residency-district plan is not unconstitutional without factual proof of vote dilution.
- Allows counties to use countywide voting with residency-based candidate districts absent specific proof of dilution.
- Makes it harder for city residents to block such plans without case-specific factual proof.
- Remands cases for further proceedings rather than resolving factual claims.
Summary
Background
Residents of the city of Selma sued to challenge how members of the Dallas County Commission are chosen. Alabama law required each commissioner to live in one of four residency districts while every voter in the county voted in each race. The city of Selma contains about half the county’s population, yet the plan made it likely that only one Selma resident could serve on the four-member commission. The federal district court granted summary judgment for the county, relying on earlier cases. The Court of Appeals for the Fifth Circuit reversed in an en banc decision, finding that the unequal districts diluted Selma residents’ votes.
Reasoning
The Court examined whether countywide elections combined with residency rules violate the Constitution without evidence that the plan actually weakens an identifiable group’s voting power. Citing earlier decisions, the Court explained that officials elected by the whole county must serve and represent the entire county, and that residency districts serve only as candidate residence qualifications. The appeals court relied on a presumption that officials would favor their home districts, but the Supreme Court said that presumption conflicts with precedent and cannot replace factual proof that a plan operates to dilute votes. The Supreme Court reversed the Court of Appeals and sent the case back for further proceedings consistent with this view.
Real world impact
Counties with similar systems can no longer be struck down on theory alone; challengers must show concrete, case-specific evidence that the plan actually dilutes an identifiable group’s voting strength. The decision affects Selma residents and other communities contesting residency-based election plans. The case was reversed and remanded rather than finally resolving all factual claims.
Dissents or concurrances
One judge on the Court of Appeals would have sent the case back for an evidentiary hearing to decide whether invidious discrimination occurred. Justice Douglas did not participate in this decision.
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