Easley v. Cromartie

Easley v. Cromartie, 532 U.S. 234 (2001), is an appeal of the United States Supreme Court case Hunt v Cromartie. The case defendant is Mike Easley, who became North Carolina governor following Jim Hunt. The court's ruling on April 18, 2001 stated that redistricting for political reasons did not violate Federal Civil Rights Law banning race-based gerrymandering. (Case No. 99-1864).

Easley v. Cromartie (also known as Hunt v. Cromartie)
Argued November 27, 2000
Decided April 18, 2001
Full case nameMichael F. Easley, Governor of North Carolina v. Martin Cromartie, et al.
Citations532 U.S. 234 (more)
121 S. Ct. 1452; 149 L. Ed. 2d 430
Case history
PriorShaw v. Reno, 509 U.S. 630 (1993); on remand, Shaw v. Hunt, 861 F. Supp. 408 (E.D.N.C. 1994); reversed, 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
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityBreyer, joined by Stevens, O'Connor, Souter, Ginsburg
DissentThomas, joined by Rehnquist, Scalia, Kennedy

The issue facing this Supreme Court case was Constitutional validity of the Congressional Districts in North Carolina. Specifically, the 12th district which cut through the southwestern portion of the state. The complaint of the plaintiff and North Carolina citizens was that the drawing of the district violated the Equal Protection Clause of the Constitution as the district was drawn primarily amongst racial considerations.[1]

The justification of the court stated that in North Carolina, race and politics are strongly correlated. The district may be majority African American, however, Southern Blacks have strong tendencies to vote Democrat.[1] Voter registrations were used as evidence to prove to the court that the redistricting which drew the 12th district were arguably based on political reasons.[2] In the majority opinion, Stephen G Breyer says "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", and in this case, the plaintiffs were not able to make this argument compelling.[2]

Justice O'Connor previously sided with the district courts in Hunt v Cromartie, however, this instance ruled with the North Carolina legislature, acting as the all important swing vote to overturn the previous decision 5–4. The allegedly odd-shaped district was allowed to stand.

See also

References
  1. LawSchoolCaseBriefs.net. "Easley v. Cromartie case brief". Retrieved 2019-03-05.
  2. "Easley v. Cromartie, 532 U.S. 234 (2001)". Justia Law. Retrieved 2019-03-05.

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.


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