Facts of the Case
Following the Supreme Court's decision in Shaw v. Hunt (517 US 899), declaring North Carolina's 12th district to have been unconstitutionally drawn, the state made a new districting plan in 1997. Acting on behalf of other residents, Martin Cromartie again challenged the new make-up of the 12th district as the product of racial gerrymandering. However, even before an evidentiary hearing, a three-judge District Court granted Cromartie summary judgment. Hunt appealed and the Supreme Court granted him certiorari.
Questions
Is the presence of "uncontroverted material facts," concerning the practice of racial gerrymandering, sufficient to sustain a summary judgment even prior to conducting an evidentiary hearing or discovery?
Conclusions
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No. In a unanimous opinion, the Court held that despite strong evidence of racial gerrymandering, the North Carolina General Assembly's motivations were in dispute. As such, further inquiry was warranted on this alone. Moreover, since accusations of racial gerrymandering rise to the level of being constitutionally significant, they must be evaluated with strict scrutiny. Therefore, the dismissal of such serious accusations with a summary judgment was erroneous.
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