Miller v. Johnson

Miller v. Johnson, 515 U.S. 900 (1995), is a landmark decision of the United States Supreme Court.

Georgia’s congressional redistricting plan created three majority-Black districts, including one that was oddly shaped. The plan was drawn under pressure from the Department of Justice under Section 5 of the Voting Rights Act. White voters challenged the plan as racial gerrymandering, and the state argued that compliance with the Voting Rights Act justified the use of race.

Significance

Justice Kennedy’s 5-4 opinion held that race cannot be the ‘predominant factor’ in drawing district lines unless strict scrutiny is satisfied. The Court found that the Georgia plan’s shape and the process by which it was created demonstrated that race was the predominant consideration. The Voting Rights Act did not require the state to maximize majority-minority districts at the expense of traditional districting principles. Miller refined the standard for racial gerrymandering claims, focusing on the legislature’s predominant motive.

Category

US Federal Case Law