Subject: two hypotheticals to understand the current (and possibly future) section 5 of the VRA
From: Rick Hasen
Date: 6/18/2006, 8:21 PM
To: election-law

As many people on the list know, current section 5 provides that the DOJ cannot grant preclearance to a change in a voting procedure unless the jurisdiction can show that the change "does not have the purpose and will not have the effect of denying or abridging the right to vote on account of race or color, or in contravention of the guarantees set forth in section 1973b(f)(2) of this title."
The proposed revision to section 5 would further define the applicable standard to explain that

"Any voting qualification or prerequisite to voting, or standard practice or procedure with respect to voting that has the purpose of or will have the effect of diminishing the ability of any citizens of the United States on account of race or color, or in contravention of the guarantees set forth in section 4(f)(2), to elect their preferred candidates of choice denies or abridges the right to vote within the meaning of subsection (a) of this section."

So here are my two hypotheticals.  I thought it would be useful to hear from list members whether the DOJ should grant preclearance under (a) the Beer standard (pre-Georgia v. Ashcroft);
(b) the current Georgia v. Ashcroft standard; and
(c) the proposed revision to section 5. 

Discussion of these hypotheticals among list members might clarify both existing law (i.e., what does Ga. v. Ashcroft mean) and the meaning of the proposed revision.

Hypo 1:  A jurisdiction's old redistricting plan had one majority-minority district.  The new plan it submits for preclearance has no majority minority districts, but creates two "influence" districts.  Should the DOJ grant preclearance?

Hypo 2: In a jurisdiction with racially polarized voting, under the
existing plan white-preferred candidates were elected in 11 of 12 districts. The new districting plan it submits for preclearance creates a second majority minority district, so that white preferred candidates are elected in only 10 districts now.  Should the DOJ grant preclearance?

If the answer is "it depends" or "we need more information," what does it depend on and what more information would we need?

Finally, it is possible that Hypo 1 and Hypo 2 are the same jurisdiction (i.e., an existing jurisdiction with 1 majority-minority district).  Is it possible that preclearance cannot be granted for either change?

Rick













-- 
Rick Hasen
William H. Hannon Distinguished Professor of Law
Loyola Law School
919 Albany Street
Los Angeles, CA  90015-1211
(213)736-1466
(213)380-3769 - fax
rick.hasen@lls.edu
http://www.lls.edu/academics/faculty/hasen.html
http://electionlawblog.org