League of United Latin Am. Citizens, Council No. 4434 v. Clements - 999 F.2d 831 (5th Cir. 1993)

Rule:

Absent evidence that minorities have been excluded from the political process, a lack of success at the polls is not sufficient to trigger judicial intervention. Courts must undertake the additional inquiry into the reasons for, or causes of, these electoral losses in order to determine whether they were the product of "partisan politics" or "racial vote dilution," "political defeat," or "built-in bias." It is only upon concluding that a minority group's failure to prevail at the polls, that is, their failure to attract the support of white voters, was the "result" or "function" of "racial vote dilution" or "built-in bias," that a court may find that minority plaintiffs have suffered a denial or abridgment of the right to vote on account of race or color. 

Facts:

Voters and citizens' league ("voters") filed an action against defendants, state officials and judges, alleging that Texas' county-wide system of electing judges violated § 2 of the Voting Rights Act ("Act"), 42 U.S.C.S. § 1973, and the federal constitution, by diluting the voting power of certain minorities. The District Court found that the system violated the Act and divided the counties into electoral subdistricts. The Court found that the Act did not apply to judicial elections, but the Supreme Court reversed. 

Issue:

Did Texas' county-wide system of electing judges violate §2 of the Voting Rights Act (Act), 42 U.S.C.S. § 1973, and the federal constitution?

Answer:

No

Conclusion:

The Court reversed, because in most counties, there was no proof of racial dilution, and in those counties where there was marginal racial dilution, the dilution was outweighed by the state's substantial interest in linking the electoral and jurisdictional bases of the district courts. The voters did not establish proof of racial bloc voting by demonstrating that race, not partisan affiliation, was the predominant determination of political preference, nor did they offer evidence of reduced levels of black voter registration or any other factor tending to show that past discrimination affected their ability to participate in the political process.