United States v. Hays

1995-06-29

Headline: Voters who do not live in a racially targeted district cannot challenge Louisiana’s congressional map; Court limited who can sue over racial gerrymanders, vacating the lower court’s injunction and ordering dismissal.

Holding: The Court held that the four Louisiana residents lacked standing because they did not live in the racially targeted district and had not shown personal race-based classification, so the lower court’s judgment was vacated and the case dismissed.

Real World Impact:

Makes it harder for out-of-district voters to sue over alleged racial gerrymanders.
Requires plaintiffs to show they personally suffered race-based treatment in their own district.
Vacates the lower court injunction and returns the case for dismissal.

Topics: racial gerrymandering, voting maps, voting rights, who can sue over elections

Summary

Background

Four Louisiana residents from Lincoln Parish sued, claiming the State’s redrawn congressional map was a racial gerrymander because of an oddly shaped majority-minority district (District 4). A federal three-judge court struck down an earlier plan, the State replaced it with a new plan (Act 1), and the plaintiffs challenged the new map in federal court.

Reasoning

The Court focused on whether the plaintiffs had the right to bring this lawsuit at all. It explained that to sue in federal court a person must show a concrete, personal injury tied to the government action. The Court relied on its earlier racial-gerrymander decision (Shaw) but held that those who do not live in the specific racially drawn district have not shown they personally suffered a race-based classification. Because the plaintiffs offered no evidence they were personally classified by race, they lacked the necessary standing.

Real world impact

The ruling is procedural: it dismisses these plaintiffs’ case for lack of standing and vacates the lower court’s injunction against the State plan. Going forward, people who want to challenge a voting map as a racial gerrymander must show they personally live in and are harmed by the racially targeted district. The decision does not resolve whether any Louisiana map is lawful on the merits.

Dissents or concurrances

Several Justices joined the judgment but wrote separately. Justice Breyer (joined by Souter) limited the holding to out-of-district voters; Justice Stevens concurred in the judgment but emphasized different grounds about vote dilution.