North Carolina v. Covington

2018-06-28
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Headline: Court partly upholds redrawing of racially gerrymandered North Carolina districts but limits federal courts from overruling state mid‑decade map changes in Wake and Mecklenburg counties.

Holding: The Court affirmed the lower court’s remedy for four specific North Carolina districts found to be racial gerrymanders, but reversed the court’s decision to overturn the legislature’s mid‑decade map changes in Wake and Mecklenburg Counties.

Real World Impact:
  • Allows courts to redraw specific racially gerrymandered districts.
  • Restricts federal courts from undoing state mid‑decade map changes not required by federal law.
  • Permits limited use of racial data to fix unconstitutional maps, not to set quotas.
Topics: racial gerrymandering, state legislative maps, court-ordered redistricting, mid-decade redistricting

Summary

Background

A group of voters sued the North Carolina General Assembly after the 2011 redistricting, saying the legislature packed Black voters into many State House and Senate districts. A federal trial court found racial gerrymanders, appointed a Special Master to redraw certain lines, and ordered replacements for four specific districts and changes in several Wake and Mecklenburg County House districts. The State appealed directly to this Court, which reviewed the remedial rulings.

Reasoning

The main questions were whether some of the new legislative districts still sorted voters by race and whether the federal court went too far in changing other state maps. The Court said the plaintiffs’ claims were still live because they showed they remained segregated by race in particular districts. It agreed that the shapes and demographics of four districts supported the trial court’s finding of ongoing race-based sorting and that a court remedy for those districts was appropriate. At the same time, the Court held the trial court had no authority to override the legislature’s decisions about mid‑decade map changes in Wake and Mecklenburg Counties when those changes were not required by federal law.

Real world impact

The decision allows federal courts to order fixes when particular districts continue to segregate voters by race, while also making clear that courts should not unduly substitute their own map choices for state legislatures except to the extent required to cure a federal violation. Voters in the affected North Carolina districts, state mapmakers, and future remedial proceedings will feel these limits on when and how courts can redraw maps.

Dissents or concurrances

Justice Thomas dissented from the summary handling of the case, saying these complex issues deserved full briefing and oral argument.

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