Thornburg v. Gingles
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redistricting procedures |
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2020 |
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Thornburg v. Gingles, a case decided by the United States Supreme Court in 1986, rendered districts of the General Assembly of North Carolina invalid on the basis that the districts impaired the ability of black voters to elect candidates of their choice. In this ruling, the high court established three criteria for analyzing claims of vote dilution.[1]
Background
In 1982, the General Assembly of North Carolina enacted a redistricting plan for the state legislature. Black citizens of North Carolina challenged seven of these districts, one single-member and six multimember. The citizens brought suit in federal district court, challenging the districts on the grounds that the planned districts impaired their ability to elect representatives of their choice in violation of Section 2 of the Voting Rights Act and the Fourteenth and Fifteenth amendments of the United States Constitution. Before the trial, Congress amended Section 2 of the Voting Rights Act to clarify that discriminatory effect by itself (as opposed to intent) was enough to prove a violation. The district court applied this criterion, and found the districting plan violated Section 2. The attorney general of North Carolina appealed directly to the U.S. Supreme Court.[2]
Decision
In a unanimous decision, the U.S. Supreme Court held that the districting plan violated Section 2 of the Voting Rights Act, ruling that the assembly’s plan diluted the minority vote by apportioning black voters into districts where white voters would defeat their preferred candidates. [3] The court ruled that plaintiffs must show a pattern of racially polarized voting, and that districts showing such a pattern could be in violation of Section 2.
The court established three criteria for proving racial vote dilution under the Voting Rights Act:
- A minority group must demonstrate it is large and compact enough to constitute a majority in a single-member district.
- A minority group must demonstrate it is politically cohesive.
- A minority group must demonstrate the majority group votes sufficiently as a group to defeat the minority group’s preferred candidate.[1][4]
Justice William Brennan wrote the following in the court’s opinion:[2]
| “ | The language of § 2 and its legislative history plainly demonstrate that proof that some minority candidates have been elected does not foreclose a § 2 claim. […] Where multimember districting generally works to dilute the minority vote, it cannot be defended on the ground that it sporadically and serendipitously benefits minority voters.[5] | ” |
| —Justice William Brennan | ||
The court also ruled that plaintiffs do not need to prove discriminatory intent or causation.[2]
See also
External links
Footnotes
- ↑ 1.0 1.1 United States Commission on Civil Rights, "Voting Rights and Political Representation in the Mississippi Delta," accessed June 3, 2015
- ↑ 2.0 2.1 2.2 Justia.com, "Thornburg v. Gingles :: 478 U.S. 30 (1986)," accessed June 3, 2015
- ↑ The Oyez Project at IIT Chicago-Kent College of Law, "THORNBURG v. GINGLES," accessed June 3, 2015
- ↑ Minnesota Senate, "4. Racial and Ethnic Discrimination," accessed June 3, 2015
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
