Alabama Legislative Black Caucus v. Alabama

Background

Two voting-rights groups — the Alabama Legislative Black Caucus and the Alabama Democratic Conference — challenged Alabama’s 2012 redrawing of 105 State House and 35 State Senate districts. Alabama prioritized near‑perfect population equality (about 1% deviation) and compliance with the Voting Rights Act, and in several majority‑black districts it added large numbers of black residents (for example, one Senate district gained 15,785 people while only 36 of them were white). A three‑judge District Court rejected the groups’ claims that the State racially gerrymandered particular districts.

Reasoning

The Supreme Court found multiple legal errors in the District Court’s handling. The lower court improperly treated the challengers’ claims as applying to the State “as a whole” instead of district‑by‑district. It also erred by denying the Conference a chance to prove it had members living in challenged districts. The Court said the District Court misapplied the test for when race “predominates” by treating the equal‑population goal as just another competing factor, and it misread Section 5 of the Voting Rights Act by treating raw percentage maintenance as the only way to avoid retrogression. For those reasons the Court vacated the judgment and sent the cases back for more focused proceedings; parties may present additional evidence.

Real world impact

The decision requires district courts to examine individual districts rather than dismiss statewide challenges, and it forces new factual and legal analysis about whether race, not population rules, drove particular boundary choices. The ruling is not a final determination on guilt or innocence; it sends the cases back for further fact-finding and legal testing.

Dissents or concurrances

Several Justices dissented, arguing plaintiffs waived district‑by‑district claims, objecting to reopening the litigation, and warning the majority’s approach will complicate one‑person, one‑vote and Voting Rights Act matters.