Easley v. Cromartie
532 U.S. 234 (2001)

  • North Carolina was drawing up new congressional districts. They drew up some districts (notably the 12th) that were predominantly African-American.
    • North Carolina argued that the districts were gerrymandered in order to create a district that would be more likely to vote for a Democrat.
      • Gerrymandering is a political trick to disenfranchise the minority political party. It works like this:
        • Say a State voted 50% Republican and 50% Democrat. A Republican legislator could ‘gerrymander’ and make 10 congressional districts that were 55% Republican, and 45% Democrat, and 1 district that was almost all Democrat. That way the Republicans would win 10 House seats and the Democrats only 1, despite that fact that the State was evenly split demographically.
  • Cromartie sued, claiming that the gerrymandering violated the Equal Protection Clause of the 14th Amendment.
    • Cromartie claimed that factoring racial demographics into drawing up congressional districts was not constitutional.
    • In the past, districts had been drawn with the express purpose of disenfranchising minorities as much as possible.
  • The US Supreme Court found that the gerrymandering was constitutional.
    • The US Supreme Court found that the strangely-shaped districts were drawn based on voting behavior, not on racial characteristics.
      • The Court considered it a coincidence that most of the Democratic voters in North Carolina happened to be minorities.
        • “In a case such as this where majority-minority districts are at issue and where racial identification correlates highly with political affiliation, the party attacking the legislatively drawn boundaries must show at the least that there legislature could have achieved its legitimate political objectives in alternative ways that are comparably consistent with traditional districting principles.
      • It is ok under the Equal Protection Clause to discriminate based on political affiliation.