North Carolina v. Convington
North Carolina v. Convington
Opinion
The North Carolina General Assembly redrew state legislative districts in 2011 to account for population changes revealed by the 2010 census. In May 2015, several registered North Carolina voters (here called plaintiffs) brought this action in the U.S. District Court for the Middle District of North Carolina, alleging that 28 majority-black districts in the new plan were unconstitutional racial gerrymanders. The District Court ruled for the plaintiffs in August 2016, holding that race was the predominant factor in the design of each challenged district, and that in none was that use of race "supported by a strong basis in evidence and narrowly tailored to comply with [the Voting Rights Act]."
Three weeks after the November 2016 election, the District Court ordered additional relief. In addition to setting a March 2017 deadline for the General Assembly's drawing of new districts, the court ordered that "[t]he term of any legislator elected in 2016" from a district later modified by that remedial plan "shall be shortened to one year" (rather than the regular two).
North Carolina appealed the District Court's remedial order to this Court, and we granted a stay pending appeal. See 580 U.S. ----,
Relief in redistricting cases is " 'fashioned in the light of well-known principles of equity.' "
Reynolds v. Sims,
Rather than undertaking such an analysis in this case, the District Court addressed the balance of equities in only the most cursory fashion. As noted above, the court simply announced that "[w]hile special elections have costs," those unspecified costs "pale in comparison" to the prospect that citizens will be "represented by legislators elected pursuant to a racial gerrymander." App. to Juris. Statement 200. That minimal reasoning would appear to justify a special election in
every
racial-gerrymandering case-a result clearly at odds with our demand for careful case-specific analysis. For that reason, we cannot have confidence that the court adequately grappled with the interests on both sides of the remedial question before us. And because the District Court's discretion "was barely exercised here," its order provides no meaningful basis for even deferential review.
Winter v. Natural Resources Defense Council, Inc
.,
For these reasons, we vacate the District Court's remedial order and remand the case for further proceedings consistent with this opinion.
It is so ordered.
By separate order, we have summarily affirmed the District Court's ruling on the merits of the plaintiffs' racial-gerrymandering claims. See No. 16-649, post, p. ----.
Reference
- Full Case Name
- NORTH CAROLINA, Et Al. v. Sandra Little COVINGTON, Et Al.
- Cited By
- 43 cases
- Status
- Published