Alexander v. S.C. State Conference NAACP
Overview
Overview
South Carolina redrew its congressional districts after the 2020 census, shifting roughly 30,000 Black voters out of the First Congressional District. The NAACP and a co-plaintiff challenged the map as an unconstitutional racial gerrymander; the Supreme Court reversed 6-3, holding that the district court applied the wrong evidentiary standard and that plaintiffs had not shown race predominated over partisan motive.
The Facts
Facts
After the 2020 census, South Carolina redrew Congressional District 1, moving a large concentration of Black voters into an adjacent district. The South Carolina State Conference of the NAACP and an individual plaintiff sued, arguing the map was a racial gerrymander under the Equal Protection Clause. The district court found racial predominance and enjoined the new map.
The Issue
Issue
Whether the district court correctly found that race, rather than partisan affiliation, was the predominant factor in drawing Congressional District 1, and whether the lower court applied the proper burden-shifting framework for racial gerrymandering claims.
The Rules
Rule
To establish a racial gerrymander, plaintiffs must show that race was the predominant factor overriding traditional districting principles. When race and partisan affiliation are highly correlated, courts must apply a robust presumption that the legislature acted on partisan rather than racial grounds. Factual findings of racial predominance are reviewed for clear error.
The Application
Analysis
Because race and partisan affiliation are highly correlated in this context, the Court applied a presumption favoring partisan motives and required plaintiffs to disprove South Carolina's race-neutral explanation for removing Black voters from District 1 with clear evidence of racial predominance. The district court's finding of racial predominance was clearly erroneous because plaintiffs failed to adequately rebut the legislature's articulated partisan justification despite the substantial movement of approximately 30,000 Black voters. Under the applicable burden-shifting framework, the existence of a plausible partisan explanation was sufficient to defeat the racial gerrymandering claim when plaintiffs could not demonstrate that race, not partisanship, was the predominant motivating factor. The map therefore stood because plaintiffs had not met their burden under the presumption favoring partisan explanations when race and partisanship align.
The Conclusion
Conclusion
The Supreme Court reversed 6-3, finding the district court's racial predominance determination was clearly erroneous. Because plausible partisan explanations existed and plaintiffs did not meet their burden of disproving them, the map was permitted to stand.
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