The plaintiff's burden in a case alleging unconstitutional racial redistricting is to show, either through circumstantial evidence of a district's shape and demographics or more direct evidence going to legislative purpose, that race was the predominant factor motivating the legislature's decision to place a significant number of voters within or without a particular district. To make this showing, a plaintiff must prove that the legislature subordinated traditional race-neutral districting principles, including but not limited to compactness, contiguity, respect for political subdivisions or communities defined by actual shared interests, to racial considerations. Where these or other race-neutral considerations are the basis for redistricting legislation, and are not subordinated to race, a state can defeat a claim that a district has been gerrymandered on racial lines.
Voters challenged appellant state officials' congressional redistricting plan as violative of U.S. Const. amend. XIV. The District Court for the Southern District of Georgia invalidated the congressional redistricting plan enacted by the state. Various state officials challenged the trial court's invalidation of the plan.
Was the congressional redistricting plan violative of the Fourteenth Amendment?
The United States Supreme Court affirmed the trial court's finding. It held that the redistricting was so bizarre on its face that it was unexplainable on grounds other than race and therefore it could not be upheld unless it was narrowly tailored to achieve a compelling state interest. It further held that appellants' true interest in designing the plan was to satisfy preclearance demands under the Voting Rights Act, 42 U.S.C.S. § 1973c, and compliance with federal antidiscrimination laws alone was not a compelling state interest. The Court said that appellants' plan was not reasonably necessary under a constitutional reading and application of the substantive provisions of the federal antidiscrimination laws even if it was required in order to obtain preclearance.