Why is the case important?
The Georgia General Assembly (or, the “Assembly”) drew a congressional district that combined black metropolitan neighborhoods, with neighborhoods in which blacks predominated on the coasts. The neighborhoods were 260 miles apart and gave blacks a second district in the state containing a majority of black voters. The Appellees, voters in the Eleventh Circuit (Appellees), challenged the constitutionality of the Eleventh District was called into question.
Facts of the case
“Between 1980 and 1990, only one of Georgia’s ten congressional districts was majority-black. According to the 1990 decennial census, Georgia’s black population of 27% entitled blacks to an additional eleventh congressional seat, prompting Georgia’s General Assembly to re-draw the state’s congressional districts. After the Justice Department refused pre-clearance of several of the Assembly’s proposed new districts, the Assembly was finally successful in creating an additional majority-black district through the forming of an eleventh district. This district, however, was called a “”geographic monstrosity”” because it extended 6,784.2 square miles from Atlanta to the Atlantic Ocean. In short, “”the social, political, and economic makeup of the Eleventh District tells a tale of disparity, not community.”””
Does Shaw v. Reno require a plaintiff to show bizarreness of a district’s shape in order to make out a successful claim of racial gerrymandering?
Was sufficient evidence produced to show that the Eleventh District was the product of racial gerrymandering?
No and Yes. Appellants misconstrue the Supreme Court of the United States’ (Supreme Court) holding in Shaw v. Reno.
A district need not be bizarre in shape before there is a constitutional violation. Shape is relevant merely because it may be persuasive circumstantial evidence that considerations of race were the legislature’s predominant motivation in drawing the district lines. Parties may rely on evidence other than bizarreness of shape to establish improper intent.
In this case, the geometric shape of the Eleventh District may not have been any more bizarre than other constitutionally drawn districts in Georgia, but there was sufficient additional evidence to show that the General Assembly was motivated by a predominantly by race.
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.
- Case Brief: 1995
- Appellant: Miller
- Appellee: Johnson
- Decided by: Rehnquist Court
Citation: 515 US 900 (1995)
Argued: Apr 19, 1995
Decided: Jun 29, 1995