Cooper v. Harris
Headline: Court affirms that North Carolina illegally used race to draw two majority-Black congressional districts, upholding the lower court’s finding and blocking those race-based lines while narrowing VRA-based defenses.
Holding:
- Forces redrawing of two North Carolina congressional districts found to be race-based.
- Limits use of racial targets without strong Voting Rights Act evidence.
- Affirms high deference to trial courts on factual findings about intent.
Summary
Background
Two registered voters, David Harris and Christine Bowser, sued North Carolina officials after the State redrew congressional maps following the 2010 census. State leaders (Senator Rucho and Representative Lewis) and their consultant Dr. Thomas Hofeller altered District 1 and District 12. District 1's black voting-age population rose from about 48.6% to 52.7%; District 12's rose from about 43.8% to 50.7%. A three-judge District Court found both districts unconstitutional.
Reasoning
The Court addressed two questions: did race predominate in drawing the lines, and if so, could the State justify that choice under the Voting Rights Act? Applying clear-error review, the Justices gave deference to the District Court's factual findings and affirmed. For District 1 the record showed a stated 50% racial target, instructions to the mapmaker, and departures from usual districting practices, so race predominated; but the State lacked a strong evidentiary basis under §2 because past crossover white voting had allowed black-preferred candidates to win, so the race-based drawing failed a demanding legal test. For District 12 the Court upheld the District Court's credibility-based finding that race, not politics, predominated.
Real world impact
The ruling requires North Carolina to abandon or redraw the two race-based districts and limits future reliance on racial targets without solid evidence under the Voting Rights Act. Mapmakers must document why race-based steps are needed. The decision emphasizes that trial courts’ factual findings about motives receive strong deference on appeal.
Dissents or concurrances
Justice Thomas concurred, agreeing with the result and clear-error approach. Justice Alito (joined by others) would have required challengers to submit alternative maps to prove politics could have achieved the same partisan goals without racial effects.
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