League of Women Voters of North Carolina v. North Carolina

League of Women Voters of North Carolina v. North Carolina was a series of federal challenges to redistricting in North Carolina following the 2010 United States Census that reached the Supreme Court of the United States. The litigation involved plaintiffs including the League of Women Voters of the United States, Common Cause, and the North Carolina State Conference of the NAACP challenging plans enacted by the North Carolina General Assembly and signed by Pat McCrory. The cases addressed claims under the United States Constitution and the Voting Rights Act of 1965, raising issues about racial gerrymandering, partisan gerrymandering, and remedial powers of state courts and federal courts.

Background

After the 2010 United States Census, the North Carolina General Assembly enacted redistricting plans for the United States House of Representatives and the North Carolina Senate and North Carolina House of Representatives. The plans were signed by Governor Pat McCrory and implemented for the 2012 elections. Plaintiffs including the League of Women Voters of the United States, Common Cause, the North Carolina State Conference of the NAACP, and private voters sued in the United States District Court for the Middle District of North Carolina and the United States District Court for the Eastern District of North Carolina, alleging violations of the Fourteenth Amendment equal protection guarantees, the First Amendment associational rights, and provisions of the Voting Rights Act of 1965, particularly Section 2 and Section 5 in contexts where preclearance had been invoked historically. Parties included defendants such as the State of North Carolina, the North Carolina General Assembly, and individual legislators like Thom Tillis and Philip E. Berger.

District Court Proceedings

The district courts evaluated multiple claims, including racial gerrymandering claims under Shaw v. Reno and Miller v. Johnson, and partisan gerrymandering claims invoking precedents from Davis v. Bandemer and later decisions. In separate proceedings, three-judge panels examined remedial maps and considered evidence from experts such as James McPherson and Michael McDonald, and testimony referencing historical practices from the Civil Rights Movement era and the legislative history of the Voting Rights Act of 1965. The district courts issued rulings enjoining certain plans, ordering remedial maps, and addressing standing and justiciability questions informed by cases like Baker v. Carr, Rucho v. Common Cause, and Gill v. Whitford in their reasoning or anticipation.

Supreme Court Proceedings

Several interlocutory appeals and emergency applications brought the matters to the Supreme Court of the United States. The Court issued stays in 2014 to preserve the maps for interim elections, referencing prior stay jurisprudence such as Nken v. Holder. The Supreme Court granted certiorari on aspects of the cases and consolidated certain appeals. Briefing involved amici including Americans for Prosperity, the American Civil Liberties Union, Lawyers' Committee for Civil Rights Under Law, and scholars from institutions such as Harvard Law School, Yale Law School, and Stanford Law School. Oral arguments engaged Justices including Elena Kagan and Anthony Kennedy on standards for adjudicating partisan gerrymandering, remedial authority after state-court litigation such as decisions by the North Carolina Supreme Court, and the interplay with the Voting Rights Act of 1965.

Legal Issues and Holdings

Central legal issues included: (1) whether certain districts were racial gerrymanders in violation of the Equal Protection Clause as articulated in Shaw v. Reno and Miller v. Johnson; (2) whether partisan gerrymandering claims were justiciable under standards from Davis v. Bandemer and subsequent jurisprudence culminating in Rucho v. Common Cause; (3) the proper remedy and remedial maps authorized to district courts; and (4) the application of the Voting Rights Act of 1965 to the plans. The Supreme Court, in per curiam and plurality rulings across the related appeals, affirmed that racial considerations predominating in districting required strict scrutiny and remedial action in line with precedents like Shaw v. Reno and Miller v. Johnson, while leaving open doctrinal questions about manageable standards for partisan gerrymandering that later surfaced in Rucho v. Common Cause. The Court’s decisions vacated and remanded certain district court orders and affected election administration for the 2016 United States House of Representatives elections in North Carolina and state legislative elections.

Impact and Aftermath

The litigation influenced subsequent challenges to redistricting in North Carolina and nationwide, informing litigation strategies by parties including Common Cause, the NAACP Legal Defense and Educational Fund, and Republican organizations such as the Republican National Committee. The cases intersected with state-court adjudication in the North Carolina Supreme Court and legislative responses by the North Carolina General Assembly, including subsequent map redrawing and amendments. Academic commentary emerged from scholars affiliated with Duke University School of Law, University of North Carolina School of Law, Columbia Law School, and Georgetown University Law Center, debating standards from the cases in relation to precedents like Cooper v. Harris and Shelby County v. Holder. The litigation contributed to legal and political discourse around redistricting reform efforts promoted by groups such as FairVote and the Brennan Center for Justice, and influenced state legislation, ballot initiatives, and further Supreme Court review of redistricting doctrine.

Category:United States Supreme Court cases