[EL] Analysis of the Supreme Court's North Carolina Racial Redistricting Decision

Tue May 23 10:34:42 PDT 2017

The way to reconcile this tension, I think, is to treat the crossover
district as a *remedy* for a Section 2 violation (or a prophylactic measure
against future Section 2 liability). After all, in *every *minority
opportunity district (crossover or not), there's insufficient white bloc
voting to defeat the minority-preferred candidate. That doesn't mean that
Section 2 becomes inapplicable once the opportunity district is drawn; it
means that Section 2 has been complied with through the opportunity
district's creation.

On Tue, May 23, 2017 at 12:26 PM, Pamela S Karlan <pkarlan at stanford.edu>
wrote:

> But the third prong of Gingles is not simply that there be majority-bloc
> voting, but that that bloc voting be sufficient to defeat the minority's
> preferred candidate.  In the example from Justice Souter, while there's
> lots of bloc voting, it's not causing the defeat of the minority-preferred
> candidate.
>
>
> I agree with your larger point about remedies and the like.  I'm just
> saying that it's hard simultaneously to claim that something is a crossover
> district and that the white voters in that district vote sufficiently as a
> bloc so as usually to defeat the minority's candidate of choice (the third
> Gingles prong).
>
>
> Pamela S. Karlan
>
> Kenneth and Harle Montgomery Professor of Public Interest Law
>
> Co-Director, Supreme Court Litigation Clinic
>
> Stanford Law School
>
> karlan at stanford.edu
>
> 650-725-4851 <(650)%20725-4851>
>
>
> ------------------------------
> *From:* Nicholas Stephanopoulos <nicholas.stephanopoulos at gmail.com>
> *Sent:* Tuesday, May 23, 2017 10:22 AM
> *To:* Pamela S Karlan
> *Cc:* Pildes, Rick; law-election at department-lists.uci.edu
>
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> It's certainly true that in *some* crossover districts (like North
> Carolina's District 1), the third *Gingles* criterion can't be satisfied
> because the level of crossover voting is too high. (Though I'd note that to
> determine this with confidence, a proper racial polarization analysis would
> be better than just data on minority population share and election
> outcomes.) But there are clearly other crossover districts where the third
> *Gingles* criterion can be satisfied. Here's a good example from Justice
> Souter's dissent in *Bartlett*:
>
> "If a minority population with 49% of the CVAP can elect the candidate of
> its choice with crossover by 2% of white voters, the minority 'by
> definition' relies on white support to elect its preferred candidate. But
> this fact alone would raise no doubt, as a matter of definition or
> otherwise, that the majority-bloc-voting requirement could be met, since as
> much as 98% of the majority may have voted against the minority’s candidate
> of choice."
>
> Based on *Bartlett *and *Cooper*, I think it's now clear that (1) the
> potential existence of such a crossover district isn't enough to satisfy
> the first *Gingles* prong -- it has to be possible to draw another
> majority-minority district; but (2) such a crossover district can be
> created by a jurisdiction as a remedy for a Section 2 violation; and (3) if
> such a district is dismantled, there can be liability under Section 2
> (provided all of the *Gingles* prongs are satisfied).
>
> On Tue, May 23, 2017 at 11:46 AM, Pamela S Karlan <pkarlan at stanford.edu>
> wrote:
>
>> The discussion on the list has been very interesting.  Nick writes that
>>
>> 2. Another question left open by the Court’s case law is whether
>> crossover districts can comply with Section 2 when all three *Gingles*
>> preconditions *are* satisfied. This precise fact pattern was not before
>> the Court since there was insufficient white bloc voting in District 1 to
>> meet the third *Gingles* precondition. However, the Court’s opinion
>> hinted pretty clearly that crossover districts are acceptable Section 2
>> remedies, even under conditions of severe racial polarization.
>>
>>
>> I was a bit confused by this.  The third Gingles precondition is that "the
>> minority must be able to demonstrate that the white majority votes
>> sufficiently as a bloc to enable it - in the absence of special
>> circumstances, such as the minority candidate running unopposed, . . . -
>> usually to defeat the minority's preferred candidate."  Gingles, 478
>> U.S. at 51.  So I'm not sure that there can *be* crossover districts in
>> the face of the third Gingles precondition.
>>
>>
>> To be sure, there can be crossover districts in the face of significant
>> white bloc voting.  E.g., in a district where the electorate is 40% black
>> and black voters are entirely cohesive, the black voters' candidate of
>> choice can win even if only about 18 percent of the white electorate
>> crosses over.  But if that crossover occurs consistently, then the third
>> Gingles precondition won't be satisfied, will it?
>>
>>
>> Pamela S. Karlan
>>
>> Kenneth and Harle Montgomery Professor of Public Interest Law
>>
>> Co-Director, Supreme Court Litigation Clinic
>>
>> Stanford Law School
>>
>> karlan at stanford.edu
>>
>> 650-725-4851 <(650)%20725-4851>
>>
>>
>> ------------------------------
>> *From:* law-election-bounces at department-lists.uci.edu <
>> law-election-bounces at department-lists.uci.edu> on behalf of Pildes, Rick
>> <pildesr at mercury.law.nyu.edu>
>> *Sent:* Monday, May 22, 2017 3:18 PM
>> *To:* Nicholas Stephanopoulos
>> *Cc:* law-election at department-lists.uci.edu
>>
>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>> Racial Redistricting Decision
>>
>>
>> For those who are not steeped in these issues, I want to point out the
>> broad significance of the graph Nick Stephanopoulos included in his
>> message/post.  That graph shows that the way the VRA affected districts
>> throughout the South was to push minority voters (mainly, black voters)
>> into two predominant types of districts:  those with a 60% minority
>> voting-age population and those with a 20% voting-age minority population.
>> What this did was to dramatically reduce throughout the South the number of
>> districts in which minority voters constituted 30-50% of the voting-age
>> population.
>>
>>
>>
>> These 30-50% minority districts were the ones that tended to elect white
>> Democrats in the South.  As a result, the ranks of white Democrats in the
>> South were significantly reduced, starting in the 1990s when this system
>> went into effect.  The 20% minority population districts tended to elect
>> Republicans.  The 60% minority districts tended to elect black Democrats.
>>
>>
>>
>> Nick’s graph, aggregated across all districts in the South, sharply
>> illustrates this VRA-induced sorting.
>>
>>
>>
>> Richard H. Pildes
>>
>> Sudler Family Professor of Constitutional Law
>>
>> NYU School of Law
>>
>> 40 Washington Square South, NY, NY 10012
>>
>> 212 998-6377 <(212)%20998-6377>
>>
>>
>>
>> *From:* Nicholas Stephanopoulos [mailto:nicholas.stephanopoulos at gmail.com]
>>
>> *Sent:* Monday, May 22, 2017 4:37 PM
>> *To:* Pildes, Rick
>> *Cc:* Justin Levitt; law-election at department-lists.uci.edu
>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>> Racial Redistricting Decision
>>
>>
>>
>> A few more points to add to the analyses by Rick H., Rick P., and Justin:
>>
>>
>>
>> 1. Ever since *Gingles* itself, it has been an open question whether the
>> mere *fact* of racial polarization in voting suffices to satisfy the
>> case’s second and third prongs. (Justice Brennan’s opinion said yes, but it
>> commanded only four votes on this issue. Some lower courts—including the
>> Fifth Circuit—subsequently held that the prongs are *not* satisfied if
>> partisanship explains racial polarization.)
>>
>>
>>
>> Today the Court strongly suggests that the causes of racial polarization
>> are irrelevant. In the Court’s long discussion of crossover voting in
>> District 1, it does not mention a single potential explanation for voter
>> behavior: not partisanship, not racial animus (or its absence), not
>> socioeconomic characteristics, not anything. Instead, the Court relies
>> exclusively on the raw election returns, which indicate that substantial
>> crossover voting must be occurring since black-preferred candidates
>> consistently won elections with ~65% of the vote even though blacks made up
>> only ~48% of District 1’s population.
>>
>>
>>
>> Going forward, I expect that Section 2 plaintiffs will be able to use the
>> Court’s discussion as a powerful rejoinder to any argument that racial
>> polarization should not “count” for *Gingles* purposes if it is the
>> product of some non-racial factor. This should make it significantly easier
>> for plaintiffs to satisfy the *Gingles* preconditions, especially in
>> areas (like the Fifth Circuit) where courts had previously probed quite
>> rigorously the reasons for racial polarization.
>>
>>
>>
>> 2. Another question left open by the Court’s case law is whether
>> crossover districts can comply with Section 2 when all three *Gingles*
>> preconditions *are* satisfied. This precise fact pattern was not before
>> the Court since there was insufficient white bloc voting in District 1 to
>> meet the third *Gingles* precondition. However, the Court’s opinion
>> hinted pretty clearly that crossover districts are acceptable Section 2
>> remedies, even under conditions of severe racial polarization. In the key
>> passage, the Court quoted North Carolina’s position that if “§ 2 does not *require
>> *crossover districts . . . then § 2 also cannot be *satisfied* *by*
>> crossover districts.” This stance, declared the Court, “is at war with our
>> § 2 jurisprudence.”
>>
>>
>>
>> Several implications follow. First, jurisdictions that are successfully
>> sued under Section 2 should be able to design crossover districts as a
>> remedy for the violation. Second, Section 2 suits should fail if they are
>> used to challenge existing crossover districts (in an effort to replace
>> them with majority-minority districts). And third, as in *Cooper*,
>> jurisdictions should not be able to use Section 2 compliance as a defense
>> in a racial gerrymandering case if they convert crossover districts into
>> majority-minority districts. Arguably, all of this was implicit in
>> *Bartlett*, but it’s still important to see the Court providing
>> confirmation.
>>
>>
>>
>> 3. Finally, there are *many* majority-minority districts, both in the
>> South and elsewhere in the country, where functioning crossover districts
>> could be drawn instead. In an article
>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2336749> a few
>> years back, I created the below density curve of minority population share
>> in all districts (congressional and state legislative) in states previously
>> covered by Section 5. The distribution is clearly bimodal, with one of its
>> peaks around *60%* minority voting age population. The district
>> distribution also looks nothing like the underlying distribution of
>> minority population share at the precinct level, which is unimodal and
>> normal in shape. This suggests that the district distribution—with its many
>> majority-minority districts—is the product of intentional racial
>> redistricting.
>>
>>
>>
>> Of course, the mere fact that a crossover district could have been drawn
>> in an area where a majority-minority district was drawn instead does not
>> establish that race was the predominant factor in the district’s creation.
>> The plaintiffs in *Cooper* had much more damning evidence than that,
>> including the use of an explicit racial target. Nevertheless, it is
>> certainly relevant that many majority-minority districts are more “packed”
>> than they need to be to comply with Section 2—likely intentionally in many
>> cases. This means that *Cooper*’s reach could be greater than that of
>> the racial gerrymandering cases the Court has previously decided this cycle.
>>
>>
>>
>>  [image: Inline image 1]
>>
>>
>>
>> On Mon, May 22, 2017 at 2:18 PM, Pildes, Rick <
>> pildesr at mercury.law.nyu.edu> wrote:
>>
>> Had I know Justin was posting a critique of Rick Hasen and the NC case, I
>> would not have found a need myself to do a second post on the case to
>> explain why I reject Rick Hasen’s analysis of the decision.  I agree with
>> Justin’s critique on that, but I had already gone ahead and posted my
>> similar critique, here <http://electionlawblog.org/?p=92706>, on the
>> problems with Rick Hasen’s discussion.
>>
>>
>>
>> Best,
>>
>> Rick
>>
>>
>>
>> Richard H. Pildes
>>
>> Sudler Family Professor of Constitutional Law
>>
>> NYU School of Law
>>
>> 40 Washington Square South, NY, NY 10012
>>
>> 212 998-6377 <(212)%20998-6377>
>>
>>
>>
>> *From:* law-election-bounces at department-lists.uci.edu [mailto:
>> law-election-bounces at department-lists.uci.edu] *On Behalf Of *Justin
>> Levitt
>> *Sent:* Monday, May 22, 2017 2:55 PM
>> *To:* law-election at department-lists.uci.edu
>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>> Racial Redistricting Decision
>>
>>
>>
>> If you're looking for a reaction to the NC redistricting case from
>> someone not named Rick, I'll offer my version, now up on the Election
>> Law Blog <http://electionlawblog.org/?p=92700>.
>>
>> Though I agree with a lot of both Ricks' assessment, I pretty strongly
>> disagree with Rick Hasen that the Court just conflated race and party.
>> Indeed, I think that's the same sort of overly blunt, back-of-the-envelope
>> assessment that got the legislators in North Carolina (and several other
>> states now <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2487426>)
>> in trouble.
>>
>> Instead, I think the Court "just" reiterated the notion that whether tribally
>> partisan <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2239491>
>> motivations are themselves permissible (more to come in both the Wisconsin
>> case and in Part 6 of the North Carolina CD12 saga), it's unlawful to
>> intentionally use race as the predominant and unjustified means to that
>> end.  I put "just" in scare quotes because it's a concept that in the
>> dilution context is quite old, but legislators seem to need fairly constant
>> reminders.  And the fact that the Court issued yet another forceful
>> reminder isn't a small thing.
>>
>> (Much) more on the blog, here <http://electionlawblog.org/?p=92700>.
>>
>> Justin
>>
>> --
>>
>> Justin Levitt
>>
>> Professor of Law
>>
>> Loyola Law School | Los Angeles
>>
>> 919 Albany St.
>>
>> Los Angeles, CA  90015
>>
>> 213-736-7417 <(213)%20736-7417>
>>
>> ssrn.com/author=698321
>>
>> @_justinlevitt_
>>
>> On 5/22/2017 9:32 AM, Pildes, Rick wrote:
>>
>> I have been asked to contribute to a SCOTUS blog Symposium on today’s
>> North Carolina decision.  Here is the piece I have submitted, which I
>> wanted to circulate to the list while it is in the editing process at the
>> SCOTUS blog, for those who are trying to digest the decision now:
>>
>>
>>
>> *The Court Continues Winding Down Unnecessary Racial Redistricting  *
>>
>>
>>
>> The main take-away from today’s decision is that the Supreme Court is
>> continuing the project of winding down unnecessary racial redistricting.
>> The decision reflects the Court’s effort to modernize the Voting Rights Act
>> (VRA) and ensure it adapts to the way the dynamics of race and politics
>> have changed, in some parts of the country, in the many decades since the
>> Act first was passed.  The crucial fact in today’s decision is that 30-40%
>> of white voters in parts of North Carolina are willing to cross-over and
>> vote for the same candidates that African American voters prefer – and that
>> the VRA must reflect and recognize these changing realities.
>>
>>
>>
>> The Court today shored up the constitutional constraints limiting the use
>> of race in redistricting, which has been the main development in the law of
>> redistricting this decade.  That development began with the *Alabama *cases,
>> *Alabama Legislative Black Caucus v. Alabama, *and has now been extended
>> to Virginia and North Carolina.  And the Court also opened up a new avenue
>> of constraint by holding that if white voters now vote for candidates black
>> voters prefer at high enough rates, the intentional creation of
>> majority-black districts is no longer required – and indeed, is
>> unconstitutional.
>>
>> Let me situate today’s decision, before turning to its specifics, in the
>> broader context of the Voting Rights Act and how race came to play the role
>> it currently does in the modern era of redistricting.
>>
>> The regime of Voting Rights Act-required racial redistricting began in
>> the 1990s, in the wake of Congress’ 1982 Amendments to the VRA and the
>> Supreme Court’s 1986 decision in *Thornburg v. Gingles.  *But almost
>> immediately after the start of that regime, beginning with the *Shaw v.
>> Reno *line of cases, the Court has been struggling to cabin in and
>> constrain VRA-required race-based districting to circumstances in which it
>> is truly necessary.  In an opinion by Justice Souter back in 1994, *Johnson
>> v. DeGrandy, *the Court wrote that race-based districting under the VRA
>> relies “on a quintessentially race-conscious calculus aptly described as
>> the ‘politics of the second best.’”  A majority of the Court – confirmed by
>> the parts of today’s opinion that are unanimous – has acted on that view
>> ever since.   If the VRA truly requires race- based districting in certain
>> circumstances, that is fine.  But the Court has been extremely wary of
>> extending the regime of race-based districting anywhere beyond those
>> circumstances.
>>
>>
>>
>> Over the last 30 years, the Court has held that the VRA does not require
>> maximizing the number of minority districts, but only ensuring that
>> minority voters have an equal opportunity to elect their candidates of
>> choice; it has held that the VRA does not require (and the Constitution
>> prohibits) using irregular district shapes to create “minority opportunity”
>> districts; it has held that the VRA does not apply if minorities cannot be
>> made into the majority  in a district.  And with ever more force – as in
>> today’s decision – the Court has held that the Constitution is violated if
>> jurisdictions use the VRA to engage in race-based districting unless it is
>> clear that the VRA clearly requires doing so.  I viewed  developments as
>> moving in this direction back in a 2007 article, *The Decline of Legally
>> Mandated Representation,
>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1028607>* and since
>> then, the Court’s efforts to constrain unnecessary race-based districting
>> have become only more forceful.
>>
>>
>>
>> The most important aspect of today’s decision is the Court’s *unanimous *conclusion
>> that Congressional District 1 (CD 1) is an unconstitutional racial
>> gerrymander.  It would be easy to miss that this part of the opinion is
>> unanimous, because the Court divided 5-3 on a second district at stake, CD
>> 12.  But I have always said <https://electionlawblog.org/?p=92393> the
>> most important issue in the NC case was that involving CD 1, and there, the
>> Court was indeed unanimous.  And here, what is critical is that the Court
>> rejected North Carolina’s argument that the VRA required it to create a
>> majority-black district to make sure black voters had equal political
>> opportunity.  More specifically, the Court concluded that voting in this
>> area was not racially polarized enough to require the remedy of a
>> majority-black district.
>>
>> What does it mean for voting to be racially polarized (RPV)?  This has
>> been a key concept under the VRA, and yet the Court has given the concept
>> almost no significant attention – with today’s decision being the Court’s
>> first and thus most significant opening up of questions about this
>> concept.
>>
>>
>>
>> When RPV first entered this area of the law, the idea was simple: if 90%
>> of blacks vote for one candidate and 90% of whites vote for the opposing
>> candidate (especially when the former candidate is black), there is a clear
>> pattern of RPV.  But what happens when – as in North Carolina today –
>> roughly 30-40% of whites are willing to vote for minority candidates?
>> Since the VRA is only triggered in the redistricting area when voting is
>> racially polarized, should RPV still be considered to exist in NC when
>> there is this level of white cross-over voting support?  If the VRA still
>> applies, how does it apply when we no longer have in NC the extreme and
>> stark racial polarization of earlier decades?
>>
>>
>>
>> Here is how the Court resolves these issues as they come to bear in CD
>> 1:  for the last twenty or so years, there was enough white cross-over
>> voting support that even though the district had a black population of only
>> 46-48%, it overwhelmingly and repeated elected a black member of Congress –
>> typically, with 70% of the vote.  Yet North Carolina took the view that the
>> VRA required pump up the black population above 50% to be sure the district
>> was “safe” in ensuring for black voters an equal opportunity.  But the
>> Court held that voting cannot be considered racially polarized if there is
>> enough white cross-over support that black candidates are being elected
>> from districts that are less than 50% black.
>>
>> This conclusion is of great significance in further unwinding unnecessary
>> racial redistricting.  It means that the mechancial creation of
>> majority-minority districts will no longer be constitutionally tolerated.
>> If a cohesive black community can get its preferred candidates elected in
>> districts that are, perhaps, only 35-40% black, then pumping those
>> districts up to more than 50% black – on the view that the VRA requires it
>> – will be unconstitutional.  This opens up much more space for the creation
>> of what I have called coalitional or cross-over districts
>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=304587>, in which
>> black and white political coalitions unite behind the same candidates.
>> Indeed, as the Court today recognized, it would turn the VRA on its head if
>> the law actually required – as North Carolina insisted it did – that these
>> kind of effective coalitional districts had to be turned into
>> majority-black districts, just to ensure they are sufficiently “safe.”
>>
>>
>>
>> Put in other terms, the decision confirms that States must adhere to the
>> view that the intentional creation of majority-minority districts is a
>> “second best” remedial device, to be used only where clearly required.
>> Indeed, important parts of the opinion further emphasize that, when engaged
>> in race-based districting, States must do a thorough job of demonstrating
>> that doing so is necessary – “the State must carefully evaluate” whether
>> the facts support this, and the State must engage in a “meaningful
>> legislative inquiry” about whether doing so is necessary.
>>
>> There are other aspects of today’s decision that will also be important
>> in enforcing constitutional constraints on the excessive and unjustified
>> use of race in redistricting.  The Court said, once again, that  the
>> setting of “a racial target” that has a direct impact on the design of a
>> district means that strict scrutiny is triggered and the district can
>> survive only if the VRA requires it.
>>
>> Once again, the Court confirmed that if the State intentionally sorts
>> voters by race into districts, the State cannot hide behind the argument
>> that its ultimate goal was to pursue an effective partisan gerrymander.  To
>> the extent partisan gerrymandering is constitutional, States can sort
>> voters by their voting patterns, but not by their race.  As the Court has
>> said before, race cannot be used as a “proxy” for political voting
>> preferences.  To be sure, this can create a mess for the lower courts if a
>> State does not directly and obviously use race to sort voters; the courts
>> then have to sort out whether it was “really” race or partisan factors that
>> drove the district’s design (I have long argued that it makes little sense
>> for the Court to impose constitutional constraints on racial
>> gerrymandering, but not partisan gerrymandering).
>>
>>
>>
>> There is still more in today’s decision:  The Court held that plaintiffs
>> in these *Alabama *cases do not have provide their own alternative map
>> (which can be a costly and time consuming venture) in order to be able to
>> prove that a jurisdiction has engaged in race-based districting.  And there
>> had been a confusing couple of sentences in an earlier case, also from
>> North Carolina, that had befuddled the lower courts; the Court today
>> confines those sentences to the particular facts of that one case, as
>> Justice Thomas, who joined the majority, pointed out.  That is all to the
>> good as well.
>>
>>
>>
>> In every respect of today’s decision today, then, the Court built on the *Alabama
>> *line of cases further and made it all the more clear that the Court
>> will aggressively police the role of race in redistricting, not permit the
>> VRA to become a vehicle for excessively packing black voters into
>> districts, and will continue the project of unwinding unnecessary
>> race-based districting.
>>
>>
>>
>> Disclosure:  I argued one of the *Alabama *cases and continue to
>> represent plaintiffs in that case, which remains pending in the lower
>> courts.
>>
>>
>>
>> Richard H. Pildes
>>
>> Sudler Family Professor of Constitutional Law
>>
>> NYU School of Law
>>
>> 40 Washington Square South, NY, NY 10012
>>
>> 212 998-6377 <(212)%20998-6377>
>>
>>
>>
>> _______________________________________________
>>
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>>
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>>
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>>
>>
>>
>>
>> _______________________________________________
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>>
>>
>>
>>
>>
>> --
>>
>> Nicholas O. Stephanopoulos
>> Assistant Professor of Law
>> University of Chicago Law School
>> nsteph at uchicago.edu
>> (773) 702-4226
>> http://www.law.uchicago.edu/faculty/stephanopoulos
>>
>
>
>
> --
> Nicholas O. Stephanopoulos
> Assistant Professor of Law
> University of Chicago Law School
> nsteph at uchicago.edu
> (773) 702-4226
> http://www.law.uchicago.edu/faculty/stephanopoulos
>

-- 
Nicholas O. Stephanopoulos
Assistant Professor of Law
University of Chicago Law School
nsteph at uchicago.edu
(773) 702-4226
http://www.law.uchicago.edu/faculty/stephanopoulos
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