Thornburg v. Gingles facts for kids

Quick facts for kids Thornburg v. Gingles
Supreme Court of the United States
Argued December 4, 1985 Decided June 30, 1986
Full case name	Lacy Thornburg, Attorney General of North Carolina, et al. v. Ralph Gingles, et al.
Citations	478 U.S. 30 (more) 106 S. Ct. 2752; 92 L. Ed. 2d 25; 1986 U.S. LEXIS 121; 54 U.S.L.W. 4877; 4 Fed. R. Serv. 3d (Callaghan) 1082
Prior history	Gingles v. Edmisten], 590 F. Supp. 345 (E.D.N.C. 1984).
Holding
The inquiry into the existence of vote dilution caused by submergence in a multimember district is district specific. A successful claim under Section 2 of the Voting Rights Act of 1965 requires evidence that an affected minority group is sufficiently large to elect a representative of its choice, that the minority group is politically cohesive, and white majority voters cast their ballots sufficiently as a bloc to usually defeat the preferred candidates of the minority group.
Court membership
Case opinions
Majority	Brennan, joined by White, Marshall, Blackmun, Stevens (Parts I, II, III–A, III–B, IV–A, V); Marshall, Blackmun, Stevens (Part III–C); White (Part IV–B)
Concurrence	White
Concurrence	O'Connor (in judgment), joined by Burger, Powell, Rehnquist
Concur/dissent	Stevens, joined by Marshall, Blackmun
Laws applied
Voting Rights Act § 2

Thornburg v. Gingles was an important case decided by the Supreme Court of the United States in 1986. The Court looked at how certain election rules in North Carolina affected the voting power of Black citizens. They decided that these rules made it harder for Black voters to elect candidates they wanted.

This ruling helped change how states set up their voting districts. It led to more districts where only one person is elected, rather than several people from a larger area. This was meant to make elections fairer for all groups.

Understanding the Case: What is Vote Dilution?

The Voting Rights Act

The case was about a law called the Voting Rights Act of 1965. Section 2 of this law says that no state can make rules that stop people from voting because of their race or language. This law helps make sure everyone has an equal chance to vote.

In 1980, the Supreme Court said that to break this law, a rule had to be made on purpose to discriminate. But in 1982, Congress changed the law. They said that if a voting rule results in discrimination, it's against the law, even if it wasn't meant to be unfair. This is called the "results" test.

However, this change also said that the law doesn't guarantee that a certain group will always win a certain number of elections. It's about fairness, not about making sure a group gets a specific number of representatives.

Signs of Unfair Voting Rules

When courts look at whether a voting rule is unfair, they check several things. These are called "Senate Factors":

• A history of official discrimination in the area.
• How much people vote based on race.
• If the area uses rules that make it harder for minority groups to vote.
• If minority candidates are blocked from running for office.
• If minority groups face discrimination in areas like education or jobs.
• If political campaigns use racial messages.
• How often minority candidates have won elections.
• If elected officials listen to the concerns of minority groups.
• If the reason for the voting rule doesn't make much sense.

Courts don't need all these factors to be true to find a problem. They can also look at other evidence.

What is Vote Dilution?

The Voting Rights Act stops two main types of unfairness:

• Vote denial: This is when someone is stopped from voting or having their vote counted.
• Vote dilution: This is when a person's vote doesn't count as much as it should.

Most cases about Section 2 are about vote dilution. This often happens when election maps are drawn unfairly, or when a state uses "at-large" or "multimember" elections.

• At-large elections mean voters choose several representatives from a whole area, not just one small district.
• Multimember districts are similar; they elect more than one representative.

These systems can dilute votes if a large group can always win all the seats, leaving no chance for smaller groups.

Another way votes can be diluted is through gerrymandering. This is when election districts are drawn in strange shapes to give one political party or group an advantage.

• Packing means putting many minority voters into a few districts. This makes them win those districts easily, but they have less power in other districts.
• Cracking means spreading minority voters across many districts. This makes them a small group in each district, so they can't win any seats.

The Case in North Carolina

How the Case Started

In 1981, North Carolina redrew its election maps after the 1980 Census. Soon after, a group of people sued the state. They said that the new maps, especially the multimember districts, would make their votes count less. They believed this broke Section 2 of the Voting Rights Act.

A special court with three judges looked at the case. In 1984, they agreed that the challenged districts were unfair. They stopped North Carolina from using those maps for elections.

North Carolina's Attorney General, Lacy Thornburg, then asked the Supreme Court to review the decision. Lawyers for both sides presented their arguments to the Supreme Court in December 1985.

The Supreme Court's Decision

On June 30, 1986, the Supreme Court announced its decision. They agreed that most of North Carolina's districts were unfair.

Justice William J. Brennan Jr. wrote the main opinion for the Court. He explained a new way to decide if a voting system dilutes votes. This is now known as the Gingles test.

To prove that votes are diluted, a group must show three things:

1. The minority group is large enough and lives close enough together to form a majority in its own single-member district.
2. The minority group tends to vote together (they are "politically cohesive").
3. The majority group votes together enough to usually defeat the candidates preferred by the minority group.

If these three things are true, then the court looks at other evidence (like the "Senate Factors") to see if the voting system truly harms the minority group's ability to elect their chosen candidates.

Different Opinions from the Justices

Not all justices agreed on every detail, even if they agreed with the main outcome.

• Justice Byron White agreed with most of the decision. But he thought that the race of the candidates should also matter when looking at voting patterns, not just the race of the voters.
• Justice Sandra Day O'Connor and three other justices agreed with the final decision but had different reasons. She worried that the Court's decision might make it seem like minority groups were guaranteed a certain number of representatives, which the law didn't intend. She also agreed with Justice White that courts should look at all evidence about voting preferences, not just the race of the voters.
• Justice John Paul Stevens agreed with the main decision but disagreed about one specific district in Durham County. He felt that even though a Black candidate had been elected there, the district was still unfair because of the overall political situation in the state.

What Happened Next?

The Gingles case set up important rules for future voting rights cases.

• Later, in a case called Bartlett v. Strickland (2009), the Supreme Court said that for the first Gingles rule to be met, the minority group must be large enough to be a majority of voting-age citizens in a district. This means a group can't win a case just by getting some "crossover" votes from the majority.
• In Johnson v. De Grandy (1994), the Court added more guidance. They said that even if the three Gingles rules are met, a voting plan might not be unfair if it creates a fair number of majority-minority districts compared to the group's population. This means states don't have to create the maximum number of such districts.

One question that still isn't fully settled is whether a majority group votes as a bloc because of race, or for other reasons like political party. Courts have different ideas about how much this matters.

North Carolina continued to have issues with its election maps. In 1993, in Shaw v. Reno, the Supreme Court questioned North Carolina's attempt to create two majority-minority districts because they looked very strange. However, in 2001, in Easley v. Cromartie, the Court later said that one of these districts was okay because it was drawn for political reasons, not racial ones.