Houston Lawyers' Assn. v. Attorney General of Tex.
Headline: Court holds that the Voting Rights Act covers Texas trial judge elections, allowing minority voters to challenge at-large countywide systems and preventing a categorical exemption for single-judge elections.
Holding:
- Allows minority voters to challenge at-large county judicial elections under the Voting Rights Act.
- May lead courts or legislatures to create subdistricts or other remedies to address vote dilution.
- State interest in linking judge jurisdiction and electorate is considered but not an automatic exemption.
Summary
Background
Local chapters of the League of United Latin American Citizens and individual voters, with the Houston Lawyers’ Association as intervenors, sued the State of Texas and its officials over the at-large, countywide method for electing state district (trial) judges in ten counties. The plaintiffs said the system diluted African-American and Hispanic voting strength; for example, Harris County was about 20% African-American but had only 3 African-American district judges out of 59. A District Court found a statutory vote-dilution violation and ordered interim remedies after the legislature did not act. The Fifth Circuit sitting en banc reversed, holding that the new test in section 2 of the Voting Rights Act did not apply to judicial elections.
Reasoning
The Court asked whether section 2 of the Voting Rights Act covers trials judges’ elections. Relying on its reasoning in a companion case, the Court held that the Act does cover elections of trial judges and that the word “representatives” does not exclude judges. The Court rejected a categorical rule exempting single-member judicial offices; instead, it said a State’s interest in keeping a judge’s jurisdiction tied to the electorate is a factor to weigh in the “totality of circumstances” when deciding if vote dilution occurred. The Court reversed the Fifth Circuit and sent the cases back for further proceedings.
Real world impact
The ruling allows minority voters to bring vote-dilution claims under the Voting Rights Act against at-large county judicial election systems. Courts and legislatures may consider remedies such as creating subdistricts or other election changes, but whether a violation occurred and what remedy fits depends on the full factual record. This decision addresses threshold coverage, not the final merits of the dilution claims.
Dissents or concurrances
Justice Scalia, joined by the Chief Justice and Justice Kennedy, dissented, arguing section 2 should not apply to judicial vote-dilution claims; some Fifth Circuit judges also warned that breaking the link between a judge’s jurisdiction and electorate could reduce minority influence.
Opinions in this case:
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