North Carolina v. Convington
581 U.S. 486
SCOTUS2017Background
- In 2011 North Carolina’s General Assembly redrew state legislative districts after the 2010 census; plaintiffs challenged 28 majority-Black districts as racial gerrymanders in May 2015.
- The U.S. District Court for the Middle District of North Carolina (Aug. 2016) found race was the predominant factor in each challenged district and that race-based design was not narrowly tailored to comply with the Voting Rights Act.
- The District Court ordered the legislature to redraw maps before any future elections and, after the 2016 election, imposed remedial measures: shorten 2016-elected legislators’ terms to one year and require court-ordered special elections in fall 2017, with winners serving one-year terms.
- To facilitate special elections, the court suspended North Carolina residency requirements for prospective legislators.
- North Carolina appealed the remedial order to the Supreme Court, which granted a stay and now vacated the District Court’s remedial order for inadequate equitable analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether special elections and truncated terms are appropriate remedy for racial gerrymander | Special elections and shortened terms are necessary to cure representation harm from racial gerrymander | District court failed to meaningfully weigh equities; remedy overreached without adequate analysis | Vacated remedial order and remanded for further equitable analysis |
| Whether district court lawfully suspended state residency requirements to enable special elections | Suspension justified to implement effective remedy quickly | Such suspension implicates state sovereignty and requires careful consideration | Court found district court did not adequately weigh sovereignty and disruption concerns; remand required |
| Whether district court adequately applied equitable principles in fashioning remedy | Quick, decisive remedy required; costs pale compared to harm | District court’s explanation was cursory; failed to balance necessary factors | Remedy vacated for lack of case-specific equitable balancing |
| Standard of review for remedial redistricting relief | District court may craft relief to remedy constitutional violation | Remedy must be fashioned in light of established equitable principles and practicability | Supreme Court requires detailed, case-specific equitable analysis on remand |
Key Cases Cited
- Reynolds v. Sims, 377 U.S. 533 (1964) (equity principles guide redistricting relief)
- NAACP v. Hampton County Election Comm’n, 470 U.S. 166 (1985) (courts must undertake equitable weighing when fashioning remedies)
- New York v. Cathedral Academy, 434 U.S. 125 (1977) (remedies should be guided by what is necessary, fair, and workable)
- Swann v. Charlotte-Mecklenburg Bd. of Ed., 402 U.S. 1 (1971) (balancing individual and collective interests in remedial orders)
- Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (appellate review limited when district court’s discretion is barely exercised)