Johnson, Speaker of the Florida House of Representatives v. De Grandy

Summary

The Court held that Florida's challenged House and Senate districts did not violate § 2 of the Voting Rights Act. Satisfaction of the Gingles preconditions does not alone establish dilution, and § 2 does not require maximizing majority-minority districts. Rough proportionality between effective majority-minority districts and the minority population is relevant, but neither dispositive nor a safe harbor. The Court also rejected res judicata and Rooker/Feldman objections. It reversed the House-district ruling and affirmed the judgment leaving the Senate plan undisturbed. Justice Souter's opinion was joined by Chief Justice Rehnquist and Justices Blackmun, Stevens, O'Connor, and Ginsburg; Justice Kennedy joined except for Parts III–B-2, III–B-4, and IV. Justice O'Connor separately emphasized that proportionality is always relevant but never dispositive. Justice Kennedy concurred in part and in the judgment, recognizing proportionality's statutory relevance while warning of constitutional concerns with race-based districting. Justice Thomas, joined by Justice Scalia, dissented and would vacate and remand for dismissal because apportionment plans cannot be challenged under § 2.