Supreme Court of the United States

Alabama Legislative Black Caucus, Appellants v. Alabama Alabama Democratic Conference…

March 25, 2015575 U.S. 254

Summary

The Supreme Court vacated the district court’s judgment and remanded, holding that the lower court erred by analyzing the racial gerrymandering claim against the State as a whole, by improperly finding the Alabama Democratic Conference lacked standing, by miscalculating predominance by treating equal‑population goals as a factor, and by misinterpreting §5’s narrow‑tailoring requirement. On remand the district court must consider the claims district‑by‑district, allow the Conference to submit membership evidence, and apply strict scrutiny correctly.

Holding

  • Whether a racial gerrymandering claim must be evaluated district‑by‑district rather than against the State as a whole.. The district court’s analysis of the claim as referring to the State as a whole was legally erroneous; the claim must be assessed with respect to each individual district alleged to be gerrymandered.
  • Whether the Alabama Democratic Conference lacked standing to bring district‑specific racial gerrymandering claims.. The district court erred sua sponte in finding the Conference lacked standing; the Court must give the Conference an opportunity to submit evidence of member residency in the challenged districts.
  • How to determine whether race was the predominant factor, specifically the role of equal‑population goals.. The district court miscalculated predominance by treating the goal of roughly equal population as a non‑traditional factor to be weighed against race; equal‑population objectives are background considerations and not a factor in the Miller predominance test.
  • What the proper narrow‑tailoring inquiry under §5 requires.. The district court’s conclusion that the plan satisfied strict scrutiny was based on a misperception of §5; the statute requires maintaining a minority’s ability to elect its preferred candidate, not preserving a specific numerical minority percentage.

Docket 13-1138

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