Growe v. Emison (SCOTUS 1993), 507 U.S. 25

Summary

The Court unanimously held, in an opinion by Justice Scalia, that the District Court improperly displaced Minnesota's state-court redistricting proceedings. Federal courts must defer to timely state legislative or judicial redistricting efforts absent evidence that the State will fail to produce a lawful plan in time for elections. The District Court also had to give legal effect to the state court's completed legislative plan. The Court further held that the three Gingles prerequisites apply to Section 2 vote-dilution challenges involving single-member districts and that the record lacked evidence of minority political cohesion or majority bloc voting. It reversed and remanded with instructions to dismiss. There were no separate opinions.

Holding

Federal-court deference to state redistricting proceedings.. A federal court must defer to timely state legislative or judicial redistricting efforts unless there is evidence that the State will fail to produce a lawful plan in time for the elections. The District Court improperly obstructed and displaced those efforts here.

Effect of the state court's final legislative redistricting judgment.. The District Court had to give legal effect to the state court's adopted legislative plan rather than treat it as merely another proposed plan.

Continuing viability of claims directed at the superseded 1983 plan.. Claims that the 1983 legislative plan violated the Voting Rights Act became moot when the state court adopted its replacement, unless those claims also related to the superseding plan.

Section 2 prerequisites for single-member-district vote-dilution claims.. The three Gingles prerequisites apply to vote-dilution challenges involving single-member districts. The District Court's finding failed because the record contained neither statistical nor anecdotal evidence of minority political cohesion or majority bloc voting.

Growe v. Emison

Summary

Holding

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