Easley v. Cromartie

532 U.S. 234, 121 S. Ct. 1452 (2001)



The Supreme Court of the United States reviews a district court's findings only for clear error. In applying this standard, the court, like any reviewing court, will not reverse a lower court's finding of fact simply because it would have decided the case differently. Rather, a reviewing court must ask whether on the entire evidence, it is left with the definite and firm conviction that a mistake has been committed.


After the 1990 census, the North Carolina state legislature adopted a reapportionment plan for the state's congressional districts. The plan, as subsequently revised, included a majority-black district which was highly irregular in shape and geographically noncompact. In 1993, the United States Supreme Court held that some voters, who had alleged that the state had deliberately segregated voters into districts on the basis of race without compelling justification, stated a claim for relief under the equal protection clause of the Federal Constitution's Fourteenth Amendment. In 1996, the Supreme Court held that the plan violated the equal protection clause, because (1) race was the legislature's predominant consideration in determining the district's shape and placement; and (2) the plan was not narrowly tailored to serve a compelling state interest. After the state redrew the district's boundaries in 1997, a three-judge panel of the United States District Court for the Eastern District of North Carolina granted summary judgment to the district's challengers, on the basis of a finding that the 1997 boundaries had likewise been created with racial considerations dominating all others. On direct appeal, the Supreme Court reversed.


Did the district court err in concluding that the state violated the Equal Protection Clause?




The court found the district court's determination rested on findings such as the district's shape, its splitting of towns and counties, and its high African-American voting population. The Supreme Court had previously found this insufficient for a summary judgment. Given undisputed evidence that racial identification was highly correlated with political affiliation, such facts in and of themselves could not, as a matter of law, support the judgment. The district court relied on evidence of voting registration, not voting behavior in its "race, not politics," conclusion. That evidence was inadequate the last time the case was on appeal. None of the excluded white precincts were as reliably Democratic as the African-American precincts that were included in the district. Appellees' expert did not show a politically practical alternative plan that the legislature failed to adopt predominantly for racial reasons. References to racial balance by a senator and staff member were not persuasive. Charts summarizing evidence of voting behavior tended to refute a "race not politics" conclusion. The legislature drew its plan to protect incumbents, a legitimate political goal.

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