Hunt, Governor of North Carolina v. Cromartie
Headline: North Carolina racial-districting decision reversed: Court rejects lower court finding that the legislature drew the 1997 12th Congressional District predominantly by race, making it harder for challengers to prove racial motives.
Holding:
- Raises the burden for proving maps were drawn mainly because of race.
- Requires challengers to propose politically comparable alternative maps with better racial balance.
- Reinforces deference to legislatures when race and party closely align.
Summary
Background
North Carolina’s legislature redrew the State’s 12th Congressional District in 1997 after earlier rulings questioned the prior map. Voters and civil-rights challengers argued the legislature drew the new lines mainly because of race, not politics. A three-judge District Court held a trial and found the State had used race as the predominant factor in drawing the 1997 boundaries.
Reasoning
The Supreme Court reviewed whether the District Court had adequate evidence to say race predominated over politics. The Justices focused on whether the record supported that conclusion “on the entire evidence.” The Court examined district shape, splits of towns and counties, racial and party registration data, expert reports from Dr. Weber and Dr. Peterson, a senator’s statement about “racial and partisan balance,” and an e-mail from a legislative staff drafter. The Court emphasized that registration data can mislead because voter registration and actual voting behavior differ, especially where African-American voters vote reliably for one party. Given this close link between race and party in the area, the Court found the lower court’s factual findings clearly erroneous and concluded the evidence was also consistent with a political objective of creating a safe Democratic seat.
Real world impact
The Court reversed the District Court’s judgment that the State violated the Constitution’s ban on using race as the predominant reason for government action. The decision raises the evidentiary bar for future challengers: they must show that alternative maps could meet the legislature’s political goals while producing significantly greater racial balance. The ruling stresses caution before overturning legislative districting when race and political preference closely align.
Dissents or concurrances
Justice Thomas dissented, arguing the District Court’s factual finding should have been left intact under the usual “clear error” standard and that the lower court had sufficient evidence to find race predominant.
Opinions in this case:
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