Growe v. Emison

Background

A group of Minnesota voters sued state officials in state court about legislative and congressional districts after the 1990 census. A separate federal suit raised similar claims and alleged violations of the Voting Rights Act in parts of Minneapolis and on Indian reservations. The Minnesota Legislature passed a new map (Chapter 246) that contained technical errors; the Minnesota Special Redistricting Panel issued corrected plans. The federal District Court issued an injunction preventing the state panel from implementing its plan and later adopted its own legislative and congressional plans.

Reasoning

The Supreme Court addressed whether the federal court should have stepped in while the State’s legislature and courts were actively redrawing districts. Relying on prior decisions emphasizing state primacy in apportionment, the Court held the federal court should have deferred to the state court’s timely redistricting work. The Court also reviewed the federal court’s finding under the Voting Rights Act that Minneapolis needed a “super-majority minority” Senate district. The Supreme Court found that the federal court lacked the required evidence—statistical proof of minority political cohesion and majority bloc voting—and therefore could not impose that remedy.

Real world impact

The Court reversed the federal court’s orders and instructed dismissal of the federal action. The ruling requires federal judges to give legal effect to timely state legislative and judicial redistricting efforts and to avoid preempting them unless state branches fail to act. It also underscores that courts must rely on concrete evidence before ordering race-based remedies under the Voting Rights Act.

Dissents or concurrances

The opinion notes lower-court dissents: one judge dissented from the injunction and another judge dissented in part about the remedies, reflecting disagreement over the need for a super-majority district.