Thursday, November 7, 2013

Easley v. Cromartie case brief

Easley v. Cromartie case brief summary
532 U.S. 234 (2001)

Appellants, defenders of the North Carolina legislature's voting redistricting, appealed a judgment of the United States District Court for the Eastern District of North Carolina in favor of appellees, challengers of the redistricting, that found the legislature used race as the predominant factor in drawing a district's boundaries and, thus, violated the Equal Protection Clause of the United States Constitution.

The court found the district court's determination rested on findings such as the district's shape, its splitting of towns and counties, and its high African-American voting population. The Supreme Court had previously found this insufficient for a summary judgment. Given undisputed evidence that racial identification was highly correlated with political affiliation, such facts in and of themselves could not, as a matter of law, support the judgment.

The district court relied on evidence of voting registration, not voting behavior in its "race, not politics," conclusion. That evidence was inadequate the last time the case was on appeal. None of the excluded white precincts were as reliably Democratic as the African-American precincts that were included in the district. Appellees' expert did not show a politically practical alternative plan that the legislature failed to adopt predominantly for racial reasons. References to racial balance by a senator and staff member were not persuasive. Charts summarizing evidence of voting behavior tended to refute a "race not politics" conclusion. The legislature drew its plan to protect incumbents, a legitimate political goal.


Holding that the district court's findings were clearly erroneous, the court reversed the district court's conclusion that the state violated the Equal Protection Clause.

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