North Carolina v. Covington
The Supreme Court upheld a federal district court's replacement of four North Carolina legislative districts that still bore the marks of the racial gerrymander the Court had already found unconstitutional, but reversed the district court's decision to also redraw five unrelated House districts in Wake and Mecklenburg Counties.
The Court held that once a federal court has fixed the constitutional violation it identified, its authority to override the state legislature's map-drawing choices ends — it cannot go further and enforce a state constitutional rule that has nothing to do with the federal violation.
How it got here: A federal district court found the 2011 maps unconstitutional, appointed a Special Master to redraw four districts, and struck down five other redrawn districts; North Carolina appealed directly to the Supreme Court.
The Case in Depth
What happened
North Carolina's legislature drew 2011 state legislative districts that a group of voters challenged as racial gerrymanders, and courts agreed. After the maps were struck down, the General Assembly drew replacement maps in 2017. Voters objected that four districts still segregated people by race and that the legislature had also redrawn five unrelated House districts without a valid reason, violating a state constitutional rule against mid-decade redistricting.
The question before the Court
After courts found North Carolina's legislative maps were illegal racial gerrymanders, could a federal district court also redraw unrelated districts just because it thought the legislature broke a state redistricting rule?
Why it matters
North Carolina voters in Senate Districts 21 and 28 and House Districts 21 and 57 will vote under the court-ordered maps, while voters in the five Wake and Mecklenburg County House districts keep the legislature's own remedial map. The ruling also limits how far federal courts can go when overseeing state redistricting remedies nationwide.
What changes now
The four remedial districts drawn by the Special Master remain in place for North Carolina's elections, while the legislature's own version of the five Wake and Mecklenburg County House districts is restored. This is a final decision on the remedial dispute, though it resolves only the redistricting remedy — it does not reopen the earlier, already-affirmed finding that the original 2011 maps were unconstitutional racial gerrymanders.
What this does not decide
The Court did not revisit whether the original 2011 maps were unconstitutional — that was already decided and summarily affirmed. It also did not rule on the merits of North Carolina's mid-decade redistricting rule itself, only that a federal remedial court could not enforce it once the federal violation was fixed.
Concurrences and dissents
Dissent — Justice Thomas
“I do not think the complicated factual and legal issues in this case should be disposed of summarily.”Thomas's objection to resolving the case without briefing and argument.
Justice Thomas objected to deciding this complicated factual and legal dispute through a summary disposition without full briefing and oral argument. He did not address the merits, focusing solely on the process the Court used to resolve the case.
How the Court got there
The legal reasoning, step by step
- The Court explained that racial gerrymandering claims are based on the actual segregation of voters into districts by race, not merely on how the legislature drew the lines, so a claim survives even after new maps are enacted if the plaintiffs argue they remain segregated by race.
- The Court reaffirmed that predominant racial intent can be shown through circumstantial evidence about a district's shape and demographics, even where lawmakers say they avoided looking at race data directly, distinguishing awareness of race from being motivated by it.
- Applying that standard, the Court found the district court's detailed findings — that four districts retained the core shape, racial makeup, and boundary choices of the earlier unconstitutional districts — were unrebutted and supported the conclusion that race still predominated in those four districts.
- The Court held that a district court's own duty to remedy illegal gerrymanders in time for elections justified appointing a Special Master rather than giving the legislature another attempt, and that instructing the Special Master he could consider race only to the extent necessary to cure the violation did not amount to imposing racial quotas.
- The Court then applied the principle that state legislatures hold primary authority over redistricting and that a federal remedial court may not restrict that authority beyond what federal law actually requires, meaning a court's remedial power ends once the federal constitutional violation is cured.
- Because the five Wake and Mecklenburg County districts were redrawn only over a state constitutional dispute unrelated to the racial gerrymandering violation, the Court concluded the district court had overstepped its remedial authority in redrawing those five districts.
Doctrinal impact
Cases affected by this decision
Reaffirms Upham v. Seamon (456 U. S. 37)
Court relies on Upham's rule that federal remedial orders must not needlessly override state legislative redistricting choices.
Reaffirms North Carolina v. Covington (581 U. S. ___)
Court builds on its earlier ruling vacating the district court's first remedial order for insufficient review.