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Alabama Legislative Black Caucus v. Alabama, 13-895

In 2012, defendant Alabama redrew the boundaries of the State's House districts and Senate districts. Plaintiffs claim that Alabama's new district boundaries create a "racial gerrymander" in violation of the Fourteenth Amendment Equal Protection Clause. After a bench trial, the district court ruled in favor of the State. The judgment is vacated and remanded, where: 1) the district court's analysis of the racial gerrymandering claim as referring to the State "as a whole," rather than district-by-district, was legally erroneous; 2) the district court erred in decided that plaintiff Alabama Democratic Conference lacked standing, as in these circumstances, elementary principles of procedural fairness required that the district court, rather than acting sua sponte, give the Conference an opportunity to provide evidence of member residence; 3) the district court did not properly calculate "predominance" in its alternative holding that "race was not the predominant motivating factor" in the creation of any of the challenged districts; 4) there is strong evidence that race did predominate as a factor when the legislature drew the boundaries of Senate District 26; and 5) section 5 of the Voting Rights Act does not require a covered jurisdiction to maintain a particular numerical minority percentage, it requires that the jurisdiction maintain a minority's ability to elect a preferred candidate of choice.

Appellate Information

  • Decided 03/25/2015
  • Published 03/25/2015


  • Breyer


  • United States Supreme Court


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