While many or all of the factors under the totality of the circumstances test for challenging multimember legislative districts as violating § 2 of the Voting Rights Act of 1965, codified at 42 U.S.C.S. § 1973, may be relevant to a claim of vote dilution through submergence in multimember districts, unless there is a conjunction of other circumstances, the use of multimember districts generally will not impede the ability of minority voters to elect representatives of their choice. Stated succinctly, a bloc voting majority must usually be able to defeat candidates supported by a politically cohesive, geographically insular minority group.
The plaintiffs, United States, black voters, and Hispanic voters filed suit against the state of Florida alleging that the electoral districting lines for the state of Florida violated § 2 of the Voting Rights Act of 1965 (Act). According to the plaintiffs, the electoral districting lines fragmented ethnic boundaries and resulted in a dilution of minority voting strength. After trial, the United States District Court for the Northern District of Florida entered judgment for the plaintiffs. The defendant state then appealed.
Did the electoral districting lines for the state of Florida violate § 2 of the Voting Rights Act of 1965?
The Court held that the Act was not violated by the electoral districting lines since the districting plan allowed the voters to form effective voting majorities in a number of districts roughly proportional to their share of the voting-age population, as such, the Court concluded that there was no diminution of minority voting strength in the legislative districting plan. According to the Court, the voting laws guaranteed equality of political opportunity, not that the voters were guaranteed a number of representatives based on their population.