ABRAMS v. JOHNSON

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Case Basics
Docket No. 
95-1425
Appellee 
Johnson
Appellant 
Abrams
Consolidation 
No. 95-1460
Opinion 
Advocates
(Argued the cause on behalf of the appellees Miller et al)
(Argued the cause on behalf of the appellants Abrams et al)
(Argued the cause on behalf of the appellees Johnson, et al)
(Argued the cause on behalf of the federal appellant)
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Facts of the Case 

Following a suit by Georgia residents challenging the constitutionality of a legislative redistricting plan (Miller v. Johnson, 515 US 900), and seeking an injunction against its further use, a District Court found the plan unconstitutional. On appeal, the Supreme Court affirmed - holding that race was a predominant factor in the plan's creation - and remanded it for redrafting. Shortly thereafter the composition of another of the plan's districts was challenged in a District Court which, after unsuccessfully deferring the matter to Georgia's Legislature for redrafting, drew its own plan creating one black-majority district in place of the proposed three. After the 1996 elections were held under the court's new plan, Abrams and several other voters challenged its constitutionality. Again, the Supreme Court granted certiorari.

Question 

Did the District Court's redistricting plan violate the 1965 Voting Rights Act or Article I of the Constitution, guaranteeing "one person, one vote"?

Conclusion 
Decision: 5 votes for Johnson, 4 vote(s) against
Legal provision: Voting Rights Act of 1965

No, in a five-to-four decision. First, the Court held that in re-drafting the plans, the District Court had no obligation to preserve all three of the old plan's black-majority districts, if this would result in racial gerrymandering. Second, the Court supported the District Court's decision not to preserve two black-majority districts as it held that the area's black population was not sufficiently compact to sustain such a plan. Third, the Court ruled that the plan's creation of only one black-majority district would not violate the 1965 Voting Rights Act by causing a retrogression in the political position of Abrams and his fellow plaintiffs. The Court, in addition to noting Abrams' failure to meet his retrogression claim's population density requirement, found that in the last election, held under the challenged plan, all three black incumbents won re-election, two of whom while running against white candidates from white-majority districts. Finally, the Court concluded that the District Court's redistricting plan did not violate the Constitution's guarantee of "one person, one vote." In addition to finding that the plan's overall and average population deviations were acceptable, the Court held that even if these deviations were slightly "off" they must be tolerated given their six year tenure in an area which has seen significant population shifts. Accordingly, any minor errors would be best corrected by the next census rather than by judicial intervention.

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ABRAMS v. JOHNSON. The Oyez Project at IIT Chicago-Kent College of Law. 11 September 2014. <http://www.oyez.org/cases/1990-1999/1996/1996_95_1425>.
ABRAMS v. JOHNSON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1996/1996_95_1425 (last visited September 11, 2014).
"ABRAMS v. JOHNSON," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 11, 2014, http://www.oyez.org/cases/1990-1999/1996/1996_95_1425.