Facts: According to provisions of the Voting Rights Act of 1964, any state which wants to implement changes in “standard, practice, or procedure with respect to voting” needs pre-clearance Department of Justice approval. The State of Georgia wanted to make changes to its election districts and DOJ refused Georgia’s plans on two separate submissions. DOJ reasoned it’s rejection by asserting that Georgia had only created two different minority-majority districts and some of the minority neighborhoods were not fairly represented. Georgia submitted a third plan in which three minority-majority districts were created and DOJ finally approved it. After the 1992 elections resulted in black candidates being elected to Congress from each of the three new districts, five white voters brought suit against the state by claiming that the newly reorganized districting was unconstitutional under the Fourteenth Amendment’s equal protection clause because it constituted “racial gerrymandering.” A federal district court agreed and ruled that the creation of three new districts was not required under the Act. The eleventh district, in which the petitioners lived, covered 6,784 square miles and they claimed that it was primarily created to include widely dispersed minority neighborhoods. The state appealed the decision to the Supreme Court.
Question Presented: Were the new districts created primarily for the purpose of collecting racial minorities into majority districts in an attempt to comply with the Voting Rights Act and therefore in violation of the equal protection clause of the Fourteenth Amendment?
The Holding & Order: Yes, the Court ruled that Georgia’s districting violated the equal protection clause of the Fourteenth Amendment. The judgment of the district court was affirmed and the case remanded for further proceedings consistent with that decision.
Reasoning: The Court used Shaw v. Reno to find that from the shape of Georgia’s redistricting, it was “exceedingly obvious” that the primary motivation was to bring black voters together in racial majority districts. The Court applied strict scrutiny under the Shaw precedent. The Court views a violation of equal protection in districting when race is the primary factor, as opposed to compactness, contiguity, and respect for political subdivisions where occupants share real interests. Here, the court ruled that Georgia lacked a compelling interest since efforts to obtain approval under the Act did not constitute a compelling interest. The Court ruled that it disagreed with DOJ interpretations of the Act since those interpretations appeared to compel districting based on race alone.