Thornburg v. Gingles

1986-06-30

Headline: Voting Rights Act ruling upholds that North Carolina multimember legislative districts diluted Black voters’ power, affirming relief in most districts but reversing relief for one district.

Holding: The Court affirmed that the challenged multimember legislative districts in North Carolina violated the amended Voting Rights Act by diluting Black voters’ opportunity to elect their preferred representatives, but reversed as to House District 23.

Real World Impact:

Affirms that multimember districts can violate the Voting Rights Act.
Requires remedies where Black voters’ opportunity to elect is diluted.
Clarifies proof standards under amended §2 for vote-dilution claims.

Topics: voting rights, redistricting, racial vote dilution, multimember districts

Summary

Background

A group of Black, registered voters challenged North Carolina’s 1982 legislative redistricting plan after the State used several multimember districts. They sued, claiming the plan reduced Black voters’ ability to elect candidates of their choice under the Constitution and §2 of the Voting Rights Act, which Congress amended in 1982 to focus on results rather than officials’ intent. The District Court found vote dilution and blocked elections under the disputed parts of the plan.

Reasoning

The Supreme Court reviewed §2 and the Senate report factors and explained how plaintiffs must prove vote dilution: the minority must be large and compact enough that a single-member district could be drawn, politically cohesive, and usually defeated by a white bloc vote in the multimember scheme. The Court held that racially polarized voting means a correlation between voters’ race and candidate choice; courts need not prove racial intent or that race was the sole cause. Applying these standards, the Court affirmed the District Court’s findings of dilution in the challenged multimember districts except one.

Real world impact

The decision requires relief where multimember districts were found to dilute Black voters’ opportunities and leaves one district’s outcome reversed. State officials must address district lines or election procedures in the affected areas. The opinion also clarifies how lower courts assess §2 vote-dilution claims under the 1982 amendments.

Dissents or concurrances

Several Justices wrote separately. Justice White disagreed with treating only voter race as decisive. Justice O’Connor joined the judgment but warned the Court’s approach risks creating near-proportional representation and urged fidelity to Congress’ balance. Justice Stevens (joined by Marshall and Blackmun) would have affirmed the District Court’s ruling for all districts including District 23.