Easley v. Cromartie
| Easley v. Cromartie (also known as Hunt v. Cromartie) | |
|---|---|
| Argued November 27, 2000 Decided April 18, 2001 | |
| Full case name | Michael F. Easley, Governor of North Carolina v. Martin Cromartie, et al. |
| Citations | 532 U.S. 234 (more) 121 S. Ct. 1452; 149 L. Ed. 2d 430 |
| Case history | |
| Prior | Shaw v. Reno, 509 U.S. 630 (1993); on remand, Shaw v. Hunt, 861 F. Supp. 408 (E.D.N.C. 1994); reversed, Shaw v. Hunt, 517 U.S. 899 (1996); on remand, Cromartie v. Hunt, 34 F. Supp. 2d 1029; (E.D.N.C. 1998); reversed, Hunt v. Cromartie, 526 U.S. 541 (1999); on remand, Cromartie v. Hunt, 133 F. Supp. 2d 407 (E.D.N.C. 2000) |
| Holding | |
| The District Court's conclusion that the State violated the Equal Protection Clause in drawing the 1997 boundaries was based on clearly erroneous findings. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Breyer, joined by Stevens, O'Connor, Souter, Ginsburg |
| Dissent | Thomas, joined by Rehnquist, Scalia, Kennedy |
Easley v. Cromartie, 532 U.S. 234 (2001), is a United States Supreme Court case concerning racial gerrymandering. The Supreme Court ruled 5-4 that the factual findings of the district court that North Carolina's racial motive in drawing its 12th Congressional District predominated was clearly erroneous, instead finding the district to be a permissible partisan gerrymander.
The Supreme Court had previously directed the Eastern District of North Carolina to hold a trial on the factual question of what motive predominated when North Carolina drew the 12th Congressional District, which encompassed primarily majority-Black areas from Charlotte to Durham in a long and snakelike district. The district court found that North Carolina's racial motive predominated, rendering the district an unconstitutional racial gerrymander under the rule outlined in Shaw v. Reno, 532 U.S. 234 (2001).
The Supreme Court reversed; writing for the Court, Justice Stephen Breyer argued that the evidence which the district court had relied on failed to establish that North Carolina's racial motive had predominated, instead leaving open the possibility that race had simply been one of many factors. Breyer also wrote that the connection between race and politics throughout much of the Southern United States makes it difficult to distinguish a racial gerrymander from a partisan one: "In a case such as this one where majority-minority districts (or the approximate equivalent) 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 the legislature could have achieved its legitimate political objectives in alternative ways that are comparably consistent with traditional districting principles." In dissent, Justice Clarence Thomas argued primarily that the majority was insufficiently deferential to the factual findings of the lower court, which should be reviewed only for clear error.[1]
See also
- Shaw v. Reno, 509 U.S. 630 (1993)
- Hunt v. Cromartie, 526 U.S. 541 (1999)
- List of United States Supreme Court cases, volume 532
References
Further reading
- Kravetz, R. F. (2001). "That the District Will Be Held to Be an Unconstitutional Racial Gerrymander: Easley v. Cromartie". Duquesne Law Review. 40: 561. ISSN 0093-3058.
- Warren, C. G. (2001). "Towards Proportional Representation? The Strange Bedfellows of Racial Gerrymandering and Equal Protection in Easley v. Cromartie". Mercer Law Review. 53: 945. ISSN 0025-987X.
External links
- Text of Easley v. Cromartie, 532 U.S. 234 (2001) is available from: Google Scholar Justia Library of Congress Oyez (oral argument audio)