ALABAMA LEGISLATIVE BLACK CAUCUS v. ALABAMA

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Case Basics
Docket No. 
13-895
Petitioner 
Alabama Democratic Conference, et al.
Respondent 
Alabama, et al.
Consolidation 
13-895, Alabama Legislative Black Caucus v. Alabama
13-1138, Alabama Democratic Conference v. Alabama
Decided By 
Advocates
(for the petitioners in 13-895)
(for the petitioners in 13-1138)
(Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioner)
(for the respondents, Solicitor General, Alabama)
Term:
Facts of the Case 

The Voting Rights Act of 1965 focuses on preserving the equal representation of voters in different legislative voting districts. In 2012, the Alabama legislature redrew Alabama’s electoral districts with the goal of creating districts with a population deviation of only 1%, as opposed to the 5% courts traditionally allow when evaluating redistricting efforts. Alabama also tried to maintain the existing percentage of minority voters in each electoral district. Petitioners sued in district court and argued that Alabama’s redistricting violated the Voting Rights Act and amounted to racial gerrymandering that had negative impacts on the equal representation of racial minorities in multiple electoral districts. The district court held that the petitioners had failed to prove that Alabama used race as a “dominant and controlling” factor in redrawing its electoral districts and also that Alabama’s goal of maintaining the minority population percentages in existing districts was “narrowly tailored” to a compelling state interest. The Supreme Court noted probable jurisdiction to address the district court’s application of existing legal principles.

Question 

Did the district court apply the correct law when evaluating whether Alabama’s 2012 redistricting violated the Equal Protection Clause of the Fourteenth Amendment and the Voting Rights Act of 1965?

Conclusion 
Decision: 5 votes for Alabama Legislative Black Caucus, 4 vote(s) against
Legal provision: Section 5 of the Voting Rights Act

No. Justice Breyer delivered the opinion for the 5-4 majority. The Court held that the district court improperly considered evidence of statewide racial effects as a claim that the state used race as a factor when redrawing all of the boundary lines, when the actual allegations were that the racial gerrymandering took place in a few select electoral districts. Next, the Court held that the evidence suggested that the Caucus had standing to sue because it appeared to have members in every electoral district in the State of Alabama; the Court directed the Caucus to provide membership information sufficient to support this inference on remand. The district court also erred by considering Alabama’s goal of obtaining a 1% population deviation among districts as a relevant factor to determine whether race was a “predominate” factor in redrawing the electoral districts rather than considering the traditional goals of the Voting Rights Act. Finally, the Court rejected the district court’s holding that Alabama’s gerrymandering satisfied strict scrutiny. In application, Alabama’s interest in maintaining a particular population percentage of minority voters in each district did not equate to the Voting Rights Act’s goal of preventing “retrogression in respect to racial minorities’ ‘ability . . . to elect their preferred candidates of choice’; therefore, using a race as a factor to meet Alabama’s extraneous goals was not justified. The Court vacated and remanded the district court’s decision for further consideration consistent with its holding and additional evidence.

Justice Antonin M. Scalia authored a dissenting opinion in which he argued that the majority decision reached beyond the record because the Caucus’ complaint failed to adequately address the issues of standing and whether the allegations were a statewide claim or a select electoral district claim. Chief Justice John G. Roberts, Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent. Justice Thomas also wrote a separate dissenting opinion in which he argued that the Court’s quest to obtain “the best racial quota” was an ill-begotten one, and that Alabama’s task of complying with the convoluted goals of the Voting Rights Act was nearly impossible given all of the competing laws, jurisprudence, policies, and procedures.

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ALABAMA LEGISLATIVE BLACK CAUCUS v. ALABAMA. The Oyez Project at IIT Chicago-Kent College of Law. 31 July 2015. <http://www.oyez.org/cases/2010-2019/2014/2014_13_895%20>.
ALABAMA LEGISLATIVE BLACK CAUCUS v. ALABAMA, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2014/2014_13_895%20 (last visited July 31, 2015).
"ALABAMA LEGISLATIVE BLACK CAUCUS v. ALABAMA," The Oyez Project at IIT Chicago-Kent College of Law, accessed July 31, 2015, http://www.oyez.org/cases/2010-2019/2014/2014_13_895%20.