15-1262 Cooper V. Harris (05/22/2017).pdf

## Cooper v. Harris (2017) - Concise Summary

Issue: Does North Carolina's redrawing of two congressional districts into racially gerrymandered configurations violate the Equal Protection Clause?

Holding: Yes, the Court finds that North Carolina's actions in drawing District 1 and District 12 were primarily motivated by race and did not satisfy strict scrutiny under the Voting Rights Act (VRA).

Background: After the 2010 census, North Carolina redrew its congressional districts, significantly altering District 1 and District 12. Both districts had historically elected candidates preferred by African-American voters but no majority black voting-age population (BVAP). The new maps increased BVAP in both districts through racial sorting.

Ruling:

1. Claim Preclusion: The Court rejects North Carolina's argument that a prior state court ruling on the same issue precludes this case, finding insufficient evidence of a direct affiliation between the plaintiffs and the earlier lawsuit participants.

2. Standard of Review: The Court clarifies that clear error review applies to district court factual findings, even if inconsistent with another court's conclusions. Here, the focus is whether the District Court's assessment represents a reasonable view of the evidence.

3. Predominance of Race in District 1: The Court agrees with the District Court that race was the predominant factor in redrawing District 1. North Carolina's purposeful establishment of a racial target and its impact on district configuration support this conclusion.

4. Strict Scrutiny and VRA Justification: The State fails to show "good reasons" for believing it needed to create majority-minority districts under Section 2 of the VRA. Historical data showed African-Americans could elect their preferred candidates in District 1 without a majority, making racial gerrymandering unnecessary.

Significance: This ruling reinforces the importance of strict scrutiny and "good reasons" required for race-based districting under the Equal Protection Clause and Voting Rights Act.