Hunt, Governor of North Carolina v. Cromartie
The Supreme Court reversed a trial court's finding that North Carolina's legislature had used race as the main reason for drawing its 12th Congressional District in 1997, ruling that finding was clearly wrong given the evidence.
Because African-American voters in the district voted overwhelmingly Democratic, the Court found the evidence just as consistent with a legislature trying to protect Democratic seats as with one trying to sort voters by race, and the challengers hadn't shown otherwise.
“That is because race in this case correlates closely with political behavior.”
Explains why evidence of a heavily African-American district didn't prove a racial motive.
How it got here: A three-judge federal district court held a trial and again found the district unconstitutional; the state and other officials appealed directly to the Supreme Court.
The Case in Depth
What happened
North Carolina's legislature redrew its 12th Congressional District in 1997 after earlier versions were struck down for relying too heavily on race. Voters who opposed the new map sued again, arguing the legislature had once more sorted voters mainly by race rather than by party, even though the district's African-American residents voted overwhelmingly Democratic, making race and politics hard to separate as explanations.
The question before the Court
Did a trial court get it wrong when it found that race, not politics, drove North Carolina's 1997 redrawing of its 12th Congressional District?
The Court's answer
No — the Supreme Court found the trial court's finding was clearly erroneous. The lower court relied mainly on the district's odd shape, its splitting of towns, its heavily African-American population, and voter-registration data — evidence the Supreme Court had already said, in an earlier round of this same case, was too weak to prove race predominated when Black voters vote so overwhelmingly Democratic that race and party are hard to separate.
The Court examined additional evidence added at trial — expert testimony, a senator's comment about 'racial and partisan balance,' and a staffer's email about shifting a Black community into the district — and found it offered only modest support at best. Because the challengers never showed the legislature could have achieved the same political goals through an alternative map with meaningfully better racial balance, the finding that race predominated could not stand.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The decision makes it harder for voters challenging majority-minority districts to win when race and party preference overlap heavily, since they must show the legislature could have achieved its political goals through an alternative map with meaningfully better racial balance. That raises the practical bar for future racial-gerrymandering lawsuits in similarly polarized states.
What changes now
The trial court's ruling against the district is undone, so North Carolina's 1997 map is not struck down as an unconstitutional racial gerrymander. Because this was a final merits decision reached after a full trial, there is no further factfinding ordered; the case ends with the district's boundaries left in place, though later plans (such as one enacted in 1998) had already been used in the interim.
What this does not decide
The Court did not decide that race can never predominate in North Carolina districting, nor did it rule that all majority-minority districts drawn with awareness of race are lawful. It held only that the specific evidence relied on here was too weak to prove racial predominance given how closely race and party preference correlated.
Concurrences and dissents
Dissent — Justice Thomas
“The only question that this Court should decide is whether the District Court's finding of racial predominance was clearly erroneous.”Thomas's core objection that the majority exceeded its proper reviewing role.
Justice Thomas argued the majority abandoned true clear-error deference by conducting its own extensive factfinding rather than simply asking whether the trial court's view was permissible. He would have upheld the trial court's finding, pointing to the drafter's email about moving a 'Black community' into the district as strong direct evidence of racial motive, and stressed that courts must defer to trial judges even when the evidence is documentary or comes from experts rather than live witnesses.
How the Court got there
The legal reasoning, step by step
- Because the challengers bore a demanding burden to show a facially race-neutral map was 'unexplainable on grounds other than race,' and because courts must show extraordinary caution before second-guessing a legislature's districting choices, the Court reviewed the trial court's factual finding only for 'clear error' — asking whether it was left with a definite and firm conviction that a mistake had been made.
- The Court found that an unusually thorough review of the trial record was appropriate here because there was no intermediate appellate review, the trial was short, and the evidence was mostly documents and expert testimony rather than live credibility judgments.
- The trial court's central finding rested partly on the district's odd shape, its splitting of towns and counties, and its heavily African-American population — factors the Court had already said, in an earlier round of this same case, could not by themselves prove a racial motive when race and Democratic voting are highly correlated.
- Examining the new evidence added at trial, the Court found it relied mainly on voter registration data rather than actual voting behavior, even though white registered Democrats cross over to vote Republican far more often than African-American Democrats do — meaning a legislature chasing safe Democratic votes would naturally end up with more heavily Black precincts for political, not racial, reasons.
- The Court walked through the plaintiffs' expert testimony and two pieces of 'direct' evidence — a senator's statement about 'racial and partisan balance' and a staffer's email about moving a Black community into the district — and concluded that, at most, they offered only modest support for a racial-motive finding once weighed against the state's clear political explanation.
- Weighing this modest evidence against the strong correlation between race and party preference in North Carolina, the Court concluded the challengers had not shown that a comparably effective alternative map could have achieved the legislature's political goals with meaningfully better racial balance, so the finding of racial predominance could not stand.
Doctrinal impact
Cases affected by this decision
Reaffirms Miller v. Johnson (515 U.S. 900)
Reaffirms that legislatures deserve extraordinary caution and that race must be the predominant, not just a, motivating factor.
Reaffirms Bush v. Vera (517 U.S. 952)
Reaffirms that district lines merely correlating with race because of political sorting are not a racial classification.