Facts of the Case
The North Carolina General Assembly passed a redistricting plan for the state's Senate and House of Representatives. Black citizens of North Carolina alleged that the plan created seven new districts where blacks would not be able to elect representatives of their choosing. They filed suit in a District Court claiming that this violated Section 2 of the Voting Rights Act of 1965 and the Fourteenth and Fifteenth Amendments. Before the District Court could hear the case, Congress amended Section 2 of the Voting Rights Act in order to clarify that voting violations needed only to have a "discriminatory effect" and required no "discriminatory purpose." Considering the "totality of circumstances" of the redistricting plan, the District Court ruled that six of the new districts violated the newly amended Voting Rights Act by diluting the power of the black vote. The North Carolina Attorney General appealed the decision directly to the Supreme Court.
Questions
Did the District Court err by holding that a North Carolina redistricting plan unlawfully discriminated against blacks in six voting districts?
Conclusions
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No. The Court found that five of the six contested districts discriminated against blacks by diluting the power of their collective vote. Justice William J. Brennan Jr. delivered the opinion for a unanimous court. The District Court properly performed its function "to ascertain whether minority group members constitute a politically cohesive unit and to determine whether whites vote sufficiently as a bloc usually to defeat the minority's preferred candidate." The District Court correctly analyzed data from three election cycles in North Carolina to determine that the black voters strongly supported black candidates, whereas whites usually voted against black candidates. The redistricting plan apportioned "politically cohesive groups of black voters" into districts where blocs of white voters would consistently defeat the black candidates. In violation of the Voting Rights Act, this damaged the ability of black citizens "to participate equally in the political process and to elect candidates of their choice."
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