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Alexander v. South Carolina State Conference of the NAACP, 602 U.S. 1, 144 S.Ct. 1221, 218 L.Ed.2d 512, 23 Cal. Daily Op. Serv. 3855, 2024 Daily Journal D.A.R. 4385, 30 Fla. L. Weekly Fed. S 165

Facts

Following the 2020 Census, South Carolina had to redraw its congressional district maps due to population shifts in Districts 1 and 6. The State Senate subcommittee aimed to create a stronger Republican tilt in District 1 while adhering to traditional districting principles. The Enacted Plan increased District 1's projected Republican vote share and slightly raised the black voting-age population. The National Association for the Advancement of Colored People and a voter challenged the plan, alleging racial gerrymandering and dilution of black voters' electoral power.

Following the 2020 Census, South Carolina was tasked with redrawing its congressional district maps because of population shifts in two of its seven districts—Districts 1 and 6. The State Senate subcommittee responsible for drawing the new map issued a statement explaining that the process would be guided by traditional districting principles along with the goal of creating a stronger Republican tilt in District 1.

Issue

Did the South Carolina legislature's redistricting plan for District 1 violate the Equal Protection Clause by using race as a predominant factor in its design?

Did the South Carolina legislature's redistricting plan for District 1 violate the Equal Protection Clause by using race as a predominant factor in its design?

Rule

A legislature may pursue partisan ends in redistricting, but if race is given a predominant role, the resulting map is subjected to strict scrutiny. Plaintiffs must prove that race was the predominant factor in the legislature's decision-making process.

The Constitution entrusts state legislatures with the primary responsibility for drawing congressional districts, and legislative redistricting is an inescapably political enterprise. Claims that a map is unconstitutional because it was drawn to achieve a partisan end are not justiciable in federal court. By contrast, if a legislature gives race a predominant role in redistricting decisions, the resulting map is subjected to strict scrutiny and may be held unconstitutional.

Analysis

The Supreme Court found that the District Court's conclusion of racial predominance was clearly erroneous. The Court emphasized that the Challengers failed to provide direct evidence of a racial gerrymander and that their circumstantial evidence was weak. The Court also noted that the District Court did not adequately consider the possibility that political motivations drove the redistricting process, and the absence of an alternative map further weakened the Challengers' case.

The District Court's finding that race predominated in the design of District I in the Enacted Plan was clearly erroneous. The Challengers provided no direct evidence of a racial gerrymander, and their circumstantial evidence is very weak. Instead the Challengers relied on deeply flawed expert reports. And the Challengers did not offer a single alternative map to show that the legislature's partisan goal could be achieved while raising the BVAP in District 1.

Conclusion

The Supreme Court reversed the District Court's findings regarding racial predominance and remanded the case for further proceedings, emphasizing the need for a clear distinction between racial and political motivations in redistricting.

Reversed in part and remanded in part.

Who won?

The prevailing party was the State of South Carolina, as the Supreme Court found that the District Court had erred in its findings of racial predominance.

The Supreme Court, Justice Alito, held that: 1 finding of racial predominance, based on direct evidence that state legislature drew the challenged congressional district with racial target, was clearly erroneous.

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