Alexander v. South Carolina State Conference of the NAACP

After the 2020 census, South Carolina redrew its congressional districts. The NAACP and individual voters filed suit, alleging that the state’s First Congressional District was an unconstitutional racial gerrymander designed to move Black voters out of the district to entrench Republican advantage. The case reached the U.S. Supreme Court, which, in a 6-3 decision authored by Justice Samuel Alito, reversed the lower court’s ruling. The majority held that the district court had failed to apply a presumption of legislative good faith and that the circumstantial evidence primarily pointed to a political, rather than racial, gerrymander. The Court found that race and politics were highly correlated in South Carolina, and the plaintiffs had not sufficiently disentangled race from permissible political considerations.

The U.S. Supreme Court ruled 6-3 to reverse the lower court’s decision. The majority held that the three-judge panel clearly erred in finding that race was the predominant factor in the design of Congressional District 1, and remanded the case for further proceedings consistent with the opinion that the map did not constitute an unconstitutional racial gerrymander.

Whether South Carolina’s congressional redistricting map constituted an unconstitutional racial gerrymander in violation of the Equal Protection Clause of the Fourteenth Amendment, or whether the legislature’s predominant motive was permissible political partisanship.

The decision significantly raised the bar for plaintiffs challenging redistricting maps as racial gerrymanders, particularly in areas of the South where race and political affiliation are closely intertwined. Critics argued it gave state legislatures a virtual blueprint for disguising racial discrimination as partisan advantage, potentially weakening the protections of the Voting Rights Act. Supporters viewed it as a necessary correction to prevent federal courts from micromanaging inherently political state districting decisions. The ruling is expected to have a chilling effect on similar legal challenges across the United States ahead of future election cycles.