Bethune-Hill v. Virginia State Bd. of Elections

Bethune-Hill v. Virginia State Bd. of Elections

Argued December 5, 2016
Decided March 1, 2017
Full case name Bethune-Hill, et al. v. Virginia State Board of Elections, et al.
Docket nos. 15–680
Citations

580 U.S. ___ (more)

Prior history 141 F. Supp. 3d 505 (E.D. Va. 2015)
Procedural history On Appeal from the United States District Court for the Eastern District of Virginia
Court membership
Chief Justice
John G. Roberts
Associate Justices
Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
Majority Kennedy, joined by Roberts, Ginsburg, Breyer, Sotomayor, Kagan
Concurrence Alito (concurring in part and concurring in the judgment)
Concur/dissent Thomas
Laws applied
U.S. Const. amend. XIV

Bethune-Hill v. Virginia State Bd. of Elections, 580 U.S. ___ (2017), was a case in which the United States Supreme Court evaluated whether Virginia's legislature violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution by considering racial demographics when drawing the boundaries of twelve of the state's legislative districts.[1]

Background

This case arose when Virginia voters filed a lawsuit to challenge the twelve new legislative districts "as unconstitutional racial gerrymanders."[2] At trial, a three-Judge panel from the United States District Court for the Eastern District of Virginia ruled that race was not a predominant factor in the creation of eleven of the districts; the panel "held that race predominates only where there is an 'actual conflict between traditional redistricting criteria and race'".[3] The three-judge panel also held that race was a predominate factor for the boundaries of the remaining district, "District 75," though the panel held that the legislature did not violate the Equal Protection Clause when drawing the district "because the legislature's use of race was narrowly tailored to a compelling state interest."[4] The Panel explained "that a 55% racial target was necessary in District 75 to avoid diminishing the ability of black voters to elect their preferred candidates, which at the time would have violated §5 of the Voting Rights Act of 1965."[5]

Opinion of the Court

In an opinion written by Justice Anthony Kennedy, the Supreme Court held that the district court applied an incorrect legal standard when it determined that race did not predominate in eleven of the twelve legislative districts.[6] However, the Court also held that the district court correctly determined that legislature did not violate the constitution when drawing the boundaries of District 75.[7] The Supreme Court remanded the case back to the district court for further proceedings.[8]

See also

References

  1. Bethune-Hill v. Virginia State Bd. of Elections, No. 15–680, 580 U.S. ___ (2017), slip. op. at 1.
  2. Bethune-Hill, slip op. at 1.
  3. Bethune-Hill, slip op. at 1-2 (citing 141 F. Supp. 3d 505, 524 (E.D. Va. 2015) (internal quotation marks omitted).
  4. Bethune-Hill, slip op. at 2.
  5. Bethune-Hill, slip op. at 2 (citing Alabama Legislative Black Caucus v. Alabama, 575 U.S. ___, ___ (2015) (slip op., at 22)).
  6. Bethune-Hill, slip op. at 7-11.
  7. Bethune-Hill, slip op. at 13-16.
  8. Bethune-Hill, slip op. at 17.
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