Johnson v. De Grandy

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512 U.S. 997 (1994), argued 4 Oct. 1993, decided 30 June 1994 by a vote of 7 to 2; Souter for the Court, O’Connor concurring, Kennedy concurring in part and concurring in the judgment, Thomas and Scalia in dissent.

One of the Supreme Court's first voting rights cases after Shaw v. Reno (1993), De Grandy involved a challenge by groups of Hispanic and African voters to Florida's redistricting of Dade County's (Miami) state legislative districts after the 1990 census. The plaintiffs argued that the redistricting plan violated section 2 of the Voting Rights Act of 1965 by diluting minority voting strength. Yet the plan yielded functional proportionality in Dade County by providing a proportion of majority-minority districts that roughly equaled the proportion of the minority voting-age population.

The plaintiffs specifically argued that more majority-minority districts could have been drawn had the legislature not lessened minority voting power by packing minority voters into districts in some instances and cracking minority voting strength by dividing cohesive minority populations among multiple districts in other instances. The federal district court found that Florida's failure to create as many majority-minority districts as possible necessarily yielded a section 2 violation. In response, the Supreme Court reiterated the totality-of-the-circumstances test, finding that the plaintiffs’ evidence was insufficient to establish vote dilution in substantial measure because the plan provided rough proportionality for minority groups in the Dade County area. Justices Clarence Thomas and Antonin Scalia dissented on the grounds that an apportionment plan is not subject to section 2 challenge.

De Grandy reiterated that districting is more art than science and stressed that voting rights violations do not always flow from proof of certain background facts. Though the Court's analysis cut against the minority plaintiffs in De Grandy, its general thrust would later benefit minority voters in cases such as Easley v. Cromartie (2001).

Henry L. Chambers, Jr.

Subjects: Law.

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