Voinovich v. Quilter

Background

Ohio’s state apportionment board adopted a 1991 legislative map that initially included eight majority-minority districts after James Tilling drafted the plan and the board approved it on a 3–2 party-line vote. Two Democratic board members, joined by Democratic voters and legislators, sued in federal court arguing the plan “packed” Black voters and reduced the number of districts where Black voters could influence or elect candidates of their choice. The District Court invalidated the plan, found violations of the Voting Rights Act, the Fifteenth Amendment, and the Fourteenth Amendment, and appointed a special master to draw a new plan.

Reasoning

The Supreme Court asked whether creating majority-minority districts automatically violates the Voting Rights Act’s ban on vote dilution. It held that §2 looks only to effects: plaintiffs must prove, under the totality of circumstances, that a plan diminishes a protected group’s opportunity to elect its candidates. The Court rejected the District Court’s rule that majority-minority districts are presumptively unlawful and said the initial burden lies with plaintiffs. The Court also found the District Court’s conclusion of intentional discrimination under the Fifteenth Amendment to be clearly erroneous. Finally, the Court reversed the §2 and Fifteenth findings but kept the Fourteenth Amendment population-deviation issue for further proceedings.

Real world impact

The decision requires courts to examine actual voting effects rather than categorically forbidding majority-minority districts. It limits federal court intervention in state redistricting unless plaintiffs prove dilution or intentional discrimination. The case is remanded so the lower court can decide whether population deviations among districts exceed constitutional limits.