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Alexander v. South Carolina State Conference of the NAACP

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Supreme Court of the United States
Alexander v. South Carolina State Conference of the NAACP
Term: 2023
Important Dates
Argued: October 11, 2023
Decided: May 23, 2024
Outcome
Reversed in part and remanded in part
Vote
6-3
Majority
Samuel Alito • Chief Justice John Roberts • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Clarence Thomas (concurring in part)
Dissenting
Elena Kagan • Sonia Sotomayor • Ketanji Brown Jackson

Alexander v. South Carolina State Conference of the NAACP is a case that was decided by the Supreme Court of the United States on May 23, 2024, during the court's October 2023-2024 term. The case was argued before the Court on October 11, 2023.

The Court partially reversed the U.S. District Court for the District of South Carolina's ruling and partially remanded the case for further proceedings in a 6-3 ruling, holding "the District Court’s finding that race predominated in the design of District I in the Enacted Plan was clearly erroneous. ... Because the same findings of fact and reasoning that guided the court’s racial-gerrymandering analysis also guided the analysis of the Challengers’ independent vote-dilution claim, that conclusion also cannot stand. ... In light of these two errors in the District Court’s analysis, a remand is appropriate."[1] Justice Samuel Alito delivered the majority opinion of the court. Justice Clarence Thomas filed an opinion concurring in part. Justice Elena Kagan filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. Click here for more information about the ruling.

For more information and background about the issues presented regarding redistricting in South Carolina after the 2020 census, click here.

HIGHLIGHTS
  • The issue: The case concerned a challenge to the congressional redistricting plan that the South Carolina legislature enacted after the 2020 census.
  • The questions presented: "1. Did the district court err when it failed to apply the presumption of good faith and to holistically analyze District 1 and the General Assembly's intent?
    "2. Did the district court err in failing to enforce the alternative-map requirement m this circumstantial case?
    "3. Did the district court err when it failed to disentangle race from politics?
    "4. Did the district court err in finding racial predominance when it never analyzed District l's compliance with traditional districting principles?
    "5. Did the district court clearly err in finding that the General Assembly used a racial target as a proxy for politics when the record showed only that the General Assembly was aware of race, that race and politics are highly correlated, and that the General Assembly drew districts based on election data?
    "6. Did the district court err in upholding the intentional discrimination claim when it never even considered whether-let alone found that-District 1 has a discriminatory effect?"[2]
  • The outcome: The U.S. Supreme Court partially reversed the District of South Carolina's ruling and partially remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States District Court for the District of South Carolina. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:[3]

    • May 23, 2024: The U.S. Supreme Court partially reversed the District of South Carolina's ruling and partially remanded the case for further proceedings.
    • October 11, 2023: The U.S. Supreme Court heard oral argument.
    • May 15 2023: The U.S. Supreme Court agreed to hear the case.
    • Feb 17 2023: Thomas C. Alexander, in His Official Capacity as President of the South Carolina Senate, et al. appealed to the U.S. Supreme Court.
    • January 6, 2023: The United States District Court for the District of South Carolina ruled that Congressional District 1 was an unconstitutional racial gerrymander.[4]

    Background

    In 2021, following the 2020 Census, South Carolina’s legislature created a new congressional map for its seven house districts. This new map moved nearly 30,000 black voters out of District 1, which is currently represented by a Republican congresswoman, into District 6, which is currently represented by a Democratic congressman.[5] Portions of Beaufort, Berkeley, and Dorchester Counties, which are regarded as areas where Republican candidates perform well, were moved from District 6 into District 1.[6][7]

    The South Carolina State Conference of the NAACP filed a lawsuit against the senate leadership of the South Carolina legislature and the state’s election commission in the United States District Court for the District of South Carolina.[5] The NAACP claimed that the new map was a form of unconstitutional racial gerrymandering.T he legislature and election commission argued against racial gerrymandering, stating that the new districts were drawn to make sure that District 1 remained a safe Republican seat. The district court ruled in favor of the NAACP and ordered the South Carolina state legislature to draw a new map.[5] In Alexander v. South Carolina State Conference of the NAACP, the legislators appealed the district court’s decision to the Supreme Court.

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Did the district court err when it failed to apply the presumption of good faith and to holistically analyze District 1 and the General Assembly's intent?
    2. Did the district court err in failing to enforce the alternative-map requirement m this circumstantial case?
    3. Did the district court err when it failed to disentangle race from politics?
    4. Did the district court err in finding racial predominance when it never analyzed District l's compliance with traditional districting principles?
    5. Did the district court clearly err in finding that the General Assembly used a racial target as a proxy for politics when the record showed only that the General Assembly was aware of race, that race and politics are highly correlated, and that the General Assembly drew districts based on election data?
    6. Did the district court err in upholding the intentional discrimination claim when it never even considered whether-let alone found that-District 1 has a discriminatory effect?[8]     		”

    Oral argument

    Audio

    Audio of oral argument:[9]



    Transcript

    Transcript of oral argument:[10]

    Outcome

    The Court partially reversed the U.S. District Court for the District of South Carolina's ruling and partially remanded the case for further proceedings in a 6-3 ruling, holding "the District Court’s finding that race predominated in the design of District I in the Enacted Plan was clearly erroneous. ... Because the same findings of fact and reasoning that guided the court’s racial-gerrymandering analysis also guided the analysis of the Challengers’ independent vote-dilution claim, that conclusion also cannot stand. ... In light of these two errors in the District Court’s analysis, a remand is appropriate."[1] Justice Samuel Alito delivered the majority opinion of the court. Justice Clarence Thomas filed an opinion concurring in part. Justice Elena Kagan filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson.

    Opinion

    In the court's majority opinion, Justice Samuel Alito wrote:[1]

    “ The Constitution entrusts state legislatures with the primary responsibility for drawing congressional districts, and redistricting is an inescapably political enterprise. Legislators are almost always aware of the political ramifications of the maps they adopt, and claims that a map is unconstitutional because it was drawn to achieve a partisan end are not justiciable in federal court. Thus, as far as the Federal Constitution is concerned, a legislature may pursue partisan ends when it engages in redistricting. By contrast, if a legislature gives race a predominant role in redistricting decisions, the resulting map is subjected to strict scrutiny and may be held unconstitutional.


    These doctrinal lines collide when race and partisan preference are highly correlated. We have navigated this tension by endorsing two related propositions. First, a party challenging a map’s constitutionality must disentangle race and politics if it wishes to prove that the legislature was motivated by race as opposed to partisanship. Second, in assessing a legislature’s work, we start with a presumption that the legislature acted in good faith.

    In this case, which features a challenge to South Carolina’s redistricting efforts in the wake of the 2020 census, the three-judge District Court paid only lip service to these propositions. That misguided approach infected the District Court’s findings of fact, which were clearly erroneous under the appropriate legal standard. We therefore reverse the trial court in part and remand for further proceedings.[8]

    		”
    —Justice Samuel Alito

    Concurring opinion

    Justice Clarence Thomas filed an opinion concurring in part.

    In his concurring opinion, Justice Thomas wrote:[1]

    “ I join all but Part III–C of the Court’s opinion. The Court correctly concludes that the judgment below must be reversed under our precedents. Although I find the analysis in Part III–C persuasive, clear-error review is not an invitation for the Court to “sift through volumes of facts” and “argue its interpretation of those facts.” Easley v. Cromartie, 532 U. S. 234, 262 (2001) (THOMAS, J., dissenting). The Court’s searching review of the expert reports exceeds the proper scope of clear-error review. But, that analysis is not necessary to resolve the case. In Part III–B, the Court explains that the District Court failed to evaluate ev-idence reflecting the correlation between race and politics with the necessary presumption of legislative good faith. Ante, at 14–18. And, in Part III–D, it explains that the District Court failed to properly account for the plaintiffs’ failure to produce an alternative map. Ante, at 28–29. Both of those mistakes are reversible legal errors.


    I write separately to address whether our voting-rights precedents are faithful to the Constitution. This case is unique because it presents solely constitutional questions. The plaintiffs do not rely on the Voting Rights Act of 1965 for any of their claims. Nor do the South Carolina officials invoke the Voting Rights Act as part of their defense. There can be no more propitious occasion to consider the constitutional underpinnings of our voting-rights jurisprudence.

    ... “When, under our direction, federal courts are engaged in methodologically carving the country into racially designated electoral districts, it is imperative that we stop to consider whether the course we have charted for the Nation is the one” required by the Constitution. Holder, 512 U. S., at 945 (opinion of THOMAS, J.). The Constitution provides courts no power to draw districts, let alone any standards by which they can attempt to do so. And, it does not authorize courts to engage in the race-based reasoning that has come to dominate our voting-rights precedents. It is well past time for the Court to return these political issues where they belong—the political branches.[8]

    		”
    —Justice Clarence Thomas

    Dissenting opinion

    Justice Elena Kagan filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson.

    In her dissent, Justice Kagan wrote:[1]

    “ This voting case, as the Court acknowledges, turns on a quintessential factual dispute: Did South Carolina rely on racial data to reconfigure the State’s Congressional District 1? The parties here agree that the South Carolina Legislature wanted to make District 1 more Republican. They further agree that in pursuit of that aim, the legislature moved nearly 200,000 people into or out of the district. What the parties disagree about is how the people expelled from the district were chosen. The State contends that its mapmakers looked exclusively at data from the last election and targeted people who had voted Democratic. If that is true, the State’s actions (however unsavory and undemocratic) are immune from federal constitutional challenge. The Challengers, though, offer a different account. They say that the mapmakers, not content with what the election data revealed, also reviewed and heavily relied on racial data—thus exploiting the well-known correlation between race and voting behavior. And if that is true, the Challengers have a good constitutional claim, because the Equal Protection Clause forbids basing election districts mainly on race in order to achieve partisan aims.


    A three-judge District Court undertook to resolve that factual dispute. And the court, over nearly a year, did everything one could ask to carry out its charge. ... In the end, the court had to decide between two starkly different stories, backed by opposing bodies of evidence. One side you know from having read the majority opinion: The state officials repeatedly denied us-ing race in choosing the people kicked out of District 1, insisting that they based their decisions on political data alone. The other side you have not yet heard, except in the sketchiest of terms. It is that the State’s mapmakers were experienced and skilled in the use of racial data to draw electoral maps; that they configured their mapmaking software to show how any change made to the district would affect its racial composition; that the racial make-up they landed on was precisely what they needed, to the decimal point, to achieve their partisan goals; and that their politics-only story could not account, as a statistical matter, for their large-scale exclusion of African-American citizens.Faced with that proof, all three judges agreed: The Challengers’ version of events was the more credible. The court, to put the matter bluntly, did not believe the state officials.It thought they had gerrymandered District 1 by race.

    In reviewing those conclusions, the majority goes seriously wrong. Factfinding about electoral districting, as about other matters, is reversible “only for clear error.” Cooper, 591 U. S., at 293. This Court must give a district court’s view of events “significant deference,” which means we must uphold it so long as it is “plausible.” Ibid. Under that standard, South Carolina should now have to redraw District 1. As I’ll detail, the Challengers introduced more than enough evidence of racial gerrymandering to support the District Court’s judgment. The majority’s attempt to explain its contrary result fails at every turn. The majority picks and chooses evidence to its liking; ignores or minimizes less convenient proof; disdains the panel’s judgments about witness credibility; and makes a series of mistakes about expert opinions. The majority declares that it knows better than the District Court what happened in a South Carolina map-drawing room to produce District 1. But the proof is in the pudding: On page after page, the majority’s opinion betrays its distance from, and lack of familiarity with, the events and evidence central to this case.

    Yet there is worse: The majority cannot begin to justify its ruling on the facts without in two ways reworking the law—each to impede racial-gerrymandering cases generally. First, the majority, though ostensibly using the clear-error standard, effectively inverts it whenever a trial court rules against a redistricting State. In the majority’s version, all the deference that should go to the court’s factual findings for the plaintiffs instead goes to the losing defend-ant, because it is presumed to act in good faith. See ante, at 5. So the wrong side gets the benefit of the doubt: Any “possibility” that favors the State is treated as “dispositive.” Ante, at 16. Second, the majority invents a new rule of evidence to burden plaintiffs in racial-gerrymandering cases. As of today, courts must draw an adverse inference against those plaintiffs when they do not submit a so-called alter-native map—no matter how much proof of a constitutional violation they otherwise present. See ante, at 30–31. Such micro-management of a plaintiff ’s case is elsewhere unheard of in constitutional litigation. But as with its upside-down application of clear-error review, the majority is in- tent on changing the usual rules when it comes to addressing racial-gerrymandering claims.

    ... Perhaps most dispiriting is what lies behind the Court’s new approach—its special rules to specially disadvantage suits to remedy race-based redistricting. The Cooper dissent thought plaintiffs would use racial-gerrymandering actions as “weapons of political warfare.” Id., at 335 (ALITO, J., dissenting). And it lamented that courts finding gerrymanders were “accus[ing]” States of “offensive and demeaning conduct.” Id., at 334 (internal quotation marks omitted). So the problem was more with challenging racial gerrymanders than with putting them into place. Today, that view becomes central to the majority opinion. See ante, at 6. The suspicion, and indeed derision, of suits brought to stop racial gerrymanders are self-evident; the intent to insulate States from those suits no less so. But consider what this altered perspective misses. That a State may in fact have engaged in such “offensive and demeaning” conduct. That it may have sorted citizens by their race with respect to the most fundamental of all their political rights. That it may have done so for no reason other than to achieve partisan gain. And here, that a three-judge court unanimously found all this to have occurred.

    The proper response to this case is not to throw up novel roadblocks enabling South Carolina to continue dividing citizens along racial lines. It is to respect the plausible— no, the more than plausible—findings of the District Court that the State engaged in race-based districting. And to tell the State that it must redraw District 1, this time without targeting African-American citizens.

    ... What a message to send to state legislators and mapmakers about racial gerrymandering. For reasons I’ve addressed, those actors will often have an incentive to use race as a proxy to achieve partisan ends. See supra, at 20–22. And occasionally they might want to straight-up suppress the electoral influence of minority voters. See Cooper, 581U. S., at 319, n. 15. Go right ahead, this Court says to States today. Go ahead, though you have no recognized justification for using race, such as to comply with statutes ensuring equal voting rights. Go ahead, though you are (at best) using race as a short-cut to bring about partisan gains—to elect more Republicans in one case, more Democrats in another. It will be easy enough to cover your tracks in the end: Just raise a “possibility” of non-race-based decision-making, and it will be “dispositive.” Ante, at 16. And so this “odious” practice of sorting citizens, built on racial generalizations and exploiting racial divisions, will continue. Shaw, 509 U. S., at 643. In the electoral sphere especially, where “ugly patterns of pervasive racial discrimination” have so long governed, we should demand better—of ourselves, of our political representatives, and most of all of this Court. Id., at 639. Respectfully, I dissent.[8]

    		”
    —Justice Elena Kagan

    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, Alexander v. South Carolina State Conference of the NAACP, decided May 23, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "22-807 ALEXANDER V. SC CONFERENCE OF THE NAACP," accessed June 16, 2023
    3. ↑ U.S. Supreme Court, "22-807 ALEXANDER V. SC CONFERENCE OF THE NAACP," accessed June 16, 2023
    4. ↑ SCOTUSblog, The South Carolina State Conference of the NAACP, and Taiwan Scott, on behalf of himself and all other similarly situated persons V. Thomas C. Alexander, in his official capacity as President of the Senate; Luke A. Rankin, in his official capacity as Chairman of the Senate Judiciary Committee; G. Murrell Smith, Jr. in his official capacity as Speaker of the House of Representatives; Chris Murphy, in his official capacity as Chairman of the House of Representatives Judiciary Committee; Wallace H. Jordan, his official capacity as Chairman of the House of Representatives Elections Law Subcommittee; Howard Knapp, in his official capacity as interim Executive Director of the South Carolina State Election, decided February 4, 2023
    5. ↑ 5.0 5.1 5.2 Scotusblog, "The South Carolina State Conference of the NAACP, and Taiwan Scott, on behalf of himself and all other similarly situated persons v. Thomas C. Alexander, in his official capacity as President of the Senate; Luke A. Rankin, in his official capacity as Chairman of the Senate Judiciary Committee; G. Murrell Smith, Jr. in his official capacity as Speaker of the House of Representatives; Chris Murphy, in his official capacity as Chairman of the House of Representatives Judiciary Committee; Wallace H. Jordan, his official capacity as Chairman of the House of Representatives Elections Law Subcommittee; Howard Knapp, in his official capacity as interim Executive Director of the South Carolina State Election Commission; John Wells, Chair, JoAnne Day, Clifford J. Elder, Linda McCall, and Scott Moseley, in their official capacities as members of the South Carolina State Election Commission," December 16, 2023
    6. ↑ Oyez, "Alexander v. South Carolina State Conference of the NAACP," December 16, 2023
    7. ↑ SCOTUSblog, "Justices question finding that S.C. district was unconstitutional racial gerrymander," December 16, 2023
    8. ↑ 8.0 8.1 8.2 8.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 11, 2023
    10. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 11, 2023
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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