Abrams v. Johnson

1997-06-19

Headline: Georgia redistricting dispute: Court upholds a federal court–drawn congressional map with only one majority-black district, rejecting Voting Rights Act and population-equality challenges and leaving the map in effect.

Holding: The Court affirmed the trial court’s remedial plan, holding that a court may lawfully adopt a map with one majority-black district because plaintiffs failed to show a Voting Rights Act violation or unjustified population inequality.

Real World Impact:

Keeps the court-drawn map with one majority-black district in effect until the legislature acts.
Requires strong evidence before courts force creation of additional majority-black districts.
Permits small population deviations to respect Georgia’s county and core-district policies.

Topics: redistricting, voting rights, racial gerrymandering, one person one vote

Summary

Background

After this Court’s earlier decision in Miller that race must not predominate in drawing districts, a federal trial court redrew Georgia’s 11 congressional districts when the State legislature deadlocked. Private voters and the United States challenged the court’s new map because it contained only one majority-black district (the Fifth). The District Court had found the prior Eleventh and Second Districts were improperly drawn with race as a predominant factor, and the new court-drawn plan was used for the 1996 elections.

Reasoning

The main questions were whether the trial court exceeded its remedial power, whether the plan violated Sections 2 or 5 of the Voting Rights Act, and whether population deviations broke the one-person, one-vote rule. The Court said legislative plans deserve deference unless they were produced by racial predominance or improper Justice Department pressure. It agreed the trial court reasonably concluded a second majority-black district could not be drawn without making race the predominant factor. The Court also held the plaintiffs failed the Section 2 tests (no clear compactness or persistent racial bloc voting) and that a court-devised remedy is compared to the 1982 baseline under Section 5, with no retrogression shown. The small population deviations were justified by Georgia’s traditional districting practices and recent growth.

Real world impact

The judgment leaves the court-drawn map in place until the Georgia Legislature acts, so the single majority-black district remains effective. The opinion makes clear courts will not be required to create additional majority-black districts without strong evidence under the Voting Rights Act. It also affirms that slight population deviations in a court plan can be lawful when tied to neutral state policies and changing populations.

Dissents or concurrances

Justice Breyer (joined by three Justices) dissented, arguing the District Court should have honored the legislature’s apparent preference for two majority-black districts and that there was a strong basis in the evidence to retain two such districts under the Voting Rights Act.