Alabama Legislative Black Caucus v. Alabama

**What the Court was asked to decide** The plaintiffs – the Alabama Legislative Black Caucus and the Alabama Democratic Conference – claimed that the state’s 2012 redrawing of its House and Senate districts was an unconstitutional “racial gerrymander.” They argued that the legislature used race as the main reason for drawing the lines of certain districts, which would violate the Fourteenth Amendment’s Equal‑Protection guarantee. They also challenged the lower court’s rulings on (1) whether the Conference had standing to sue, (2) whether race was the “predominant” (most important) factor in drawing the districts, and (3) whether the state’s use of race satisfied the “strict‑scrutiny” test required when a law affects voting‑rights protections under Section 5 of the Voting Rights Act. **What the Supreme Court held** The Court vacated (set aside) the district court’s decision and sent the case back for a new trial. In plain terms, the high court said the lower court got the legal analysis wrong in several ways: 1. **District‑by‑district focus** – A racial‑gerrymander claim must be evaluated for each specific district that is alleged to have been drawn with race as the chief motive, not for the state’s entire map taken as a whole. 2. **Standing for the Conference** – The lower court improperly dismissed the Democratic Conference’s case without giving it a chance to show that its members live in the contested districts. The Court said the conference can provide a membership list and the state can respond. 3. **What counts as “predominant”** – When deciding if race predominated, the court must compare race to traditional redistricting goals (like compactness, respecting political boundaries, protecting incumbents). The goal of making every district “exactly equal in population” is not a separate factor to balance against race; it is part of the basic redistricting framework. 4. **Section 5 analysis** – The law does not require a district to keep a fixed percentage of Black voters. Instead, the state must preserve the minority voters’ ability to elect candidates of their choice. The lower court’s “numerical” test was therefore wrong. Because of these errors, the Supreme Court sent the case back for the district court to re‑examine the evidence using the correct legal standards. **How the justices voted** Justice **Breyer** wrote the majority opinion. He was joined by Justices **Kennedy, Ginsburg, Sotomayor, and Kagan** – a five‑justice majority. Justice **Scalia** wrote a dissenting opinion, joined by Chief Justice **Roberts** and Justices **Thomas and Alito**. Justice **Thomas** also filed his own separate dissent. **Why the Court reached this result (plain‑English reasoning)** - **Individual districts matter:** A claim that the state “racially gerrymandered” can’t be proved by showing that some districts were drawn without race; the plaintiffs must show that race drove the design of the specific districts they challenge. - **Fair chance to show standing:** A party can’t be thrown out of a case without being given a reasonable opportunity to prove it has a personal stake (standing). The Conference should be allowed to submit evidence of where its members live. - **Proper comparison of factors:** When the legislature decides how to draw a map, race is weighed against traditional, non‑racial goals. The “one‑percent” population‑equality rule is just a background requirement, not a separate factor that can outweigh race. - **Correct interpretation of the Voting Rights Act:** Section 5 is about keeping the power of minority voters to elect their preferred candidates, not about keeping a certain percentage of minority voters in a district. The state must show a “strong evidence‑based” reason for any race‑based decision, not just a mechanical number. In short, the Court said the lower court’s analysis was legally mistaken and that the case must be reconsidered with the proper focus on each district, proper standing, the right way to assess whether race dominated the map‑making, and the correct standard for protecting voting‑rights under Section 5.