Bethune-Hill v. Virginia State Bd. of Elections
Headline: Court clarifies how judges review race-based redistricting, upholds one Virginia district's map but sends 11 other majority‑black districts back for further review, affecting state voters and mapmakers.
Holding:
- Requires new review or redrawing of 11 Virginia legislative districts.
- Changes how courts judge race in drawing district lines.
- Leaves one district upheld based on evidence to avoid voting‑law liability.
Summary
Background
After the 2010 census, Virginia's legislature redrew state House districts and used a 55% black voting‑age population (BVAP) target in twelve majority‑black districts to preserve minority voters' ability to elect their preferred candidates. Twelve voters sued, arguing the lines were racial gerrymanders. A three‑judge federal court mostly sided with the legislature, finding race did not predominate in eleven districts and that District 75 survived strict scrutiny because the legislature had good reasons tied to the Voting Rights Act and the Department of Justice precleared the plan in 2011.
Reasoning
The Supreme Court held that the district court used the wrong test for racial predominance by treating an actual conflict with traditional mapmaking rules as a prerequisite. Instead, courts must examine whether race was the legislature's dominant motive for a district as a whole. The Court explained that challengers can rely on shape, demographics, direct evidence of intent, or other compelling evidence and that any analysis must be holistic. Applying the proper legal standards, the Court affirmed the District Court's conclusion that District 75 was narrowly tailored because legislators had a strong basis in evidence—considering turnout, past elections, a large disenfranchised prison population, and efforts by the map's architect—while vacating and remanding the other eleven districts for reconsideration under the correct standard.
Real world impact
The decision changes how judges evaluate whether race drove line‑drawing: courts must analyze each district in full rather than isolating apparent deviations from neutral criteria. District 75 remains in place for now, but eleven districts must be reexamined and could be redrawn. The ruling was not a final ruling on all maps and leaves factual findings for the lower court to revisit.
Dissents or concurrances
Justice Alito agreed with the result for District 75 and the remand for others; Justice Thomas would have reversed all twelve districts and disputed the majority's view of the Voting Rights Act and narrow tailoring.
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