Easley v. Cromarti

532 U.S. 234 (2001)

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Nature of the Case

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Facts

This 'racial districting' litigation is before the court for the fourth time. In Shaw I, the Court held that a violation may exist where the legislature's boundary drawing, though 'race-neutral on its face,' nonetheless can be understood only as an effort to 'separate voters into different districts on the basis of race,' and where the 'separation lacks sufficient justification.' In Shaw II, the Court reversed a three-judge District Court's holding that the boundary-drawing law in question did not violate the Constitution. The Court found that the district's 'unconventional,' snakelike shape, the way in which its boundaries split towns and counties, its predominately African-American racial make-up, and its history, together demonstrated a deliberate effort to create a 'majority-black' district in which race 'could not be compromised,' not simply a district designed to 'protect Democratic incumbents.' The third holding focused on a new District 12, the boundaries of which the legislature had redrawn in 1997. We agreed with the District Court that the new district's shape, the way in which it split towns and counties, and its heavily African-American voting population all helped the plaintiffs' case. But neither that evidence by itself nor when coupled with the evidence of Democratic registration, was sufficient to show, on summary judgment, the unconstitutional race-based objective that plaintiffs claimed. That is because there was a genuine issue of material fact as to whether the evidence also was consistent with a constitutional political objective, namely, the creation of a safe Democratic seat. On remand, the parties undertook additional discovery. The court again held (over a dissent) that the legislature had unconstitutionally drawn District 12's new 1997 boundaries. It found that the legislature had tried '(1) [to] cur[e] the [previous district's] constitutional defects' while also '(2) drawing the plan to maintain the existing partisan balance in the State's congressional delegation.' It added that to 'achieve the second goal,' the legislature 'drew the new plan (1) to avoid placing two incumbents in the same district and (2) to preserve the partisan core of the existing districts.' The court concluded that the 'plan as enacted largely reflects these directives.' But the court also found 'as a matter of fact that the General Assembly . . . used criteria . . . that are facially race driven' without any compelling justification for doing so. The court based its latter conclusion upon the district's snakelike shape, the way in which it split cities and towns, and its heavily African-American (47%) voting population. The Supreme Court once again granted certiorari.