McDaniel v. Sanchez

Background

Four Mexican-American residents sued Kleberg County, Texas, saying its four county commissioner districts were so unequally drawn that some votes counted less and minority voting power was diluted. A federal judge ordered the county’s elected Commissioners Court to propose a new plan. The Commissioners Court hired an outside expert, adopted his plan, and the court approved it. Opponents argued the Voting Rights Act required federal preclearance before the plan could take effect. The District Court said preclearance was unnecessary; the Court of Appeals disagreed.

Reasoning

The central question was whether a covered jurisdiction must obtain federal preclearance under the Voting Rights Act before a redistricting plan it submits to a federal court can be implemented. The Court found the statute ambiguous, so it turned to Congress’s history and purpose. The Senate report and the Act’s protective design showed Congress meant to require preclearance whenever a plan reflects the policy choices of elected officials, even if presented in litigation. The Court concluded the District Court erred by approving the county’s plan before federal review and affirmed the Court of Appeals.

Real world impact

Covered counties and other local governments must submit proposed remedial redistricting plans for federal preclearance before courts put them into effect. That gives the Justice Department or a special federal court review to prevent changes that could harm minority voting strength. The decision may slow final implementation of court-submitted plans, but district courts can fashion interim remedies to avoid leaving citizens without representation.

Dissents or concurrances

Justice Stewart (joined by Justice Rehnquist) dissented, arguing earlier cases treated plans submitted and adopted pursuant to court order as outside §5 preclearance, and he would have followed that precedent.