Narrative Opinion Summary
In this case, the plaintiffs, consisting of individual voters and associations, contested the constitutionality of the 2013 Wake County School Board Plan and the 2015 Wake County Commissioners Plan. They claimed these redistricting plans violated the one person, one vote principle under the Equal Protection Clause of the Fourteenth Amendment and the North Carolina Constitution. Despite acknowledging that the population deviations were below the 10% threshold deemed a 'minor deviation' by Supreme Court standards, the plaintiffs alleged discriminatory intent favoring rural and suburban voters and disadvantaging Democratic incumbents. Additionally, they contended that District 4 of the 2015 Commissioners Plan was racially gerrymandered. The court, however, found no evidence of invidious discrimination, arbitrary action, or racial gerrymandering. Following a bench trial, the court ruled in favor of the Wake County Board of Elections, confirming the plans' compliance with constitutional standards and allowing the continued administration of elections under these plans. The court emphasized the presumption of constitutionality for redistricting plans with minor deviations and the requirement for plaintiffs to provide substantial evidence of unconstitutional motives.
Legal Issues Addressed
Judicial Review of Redistricting Plans with Minor Population Deviationssubscribe to see similar legal issues
Application: The court emphasized the presumption of constitutionality for plans with population deviations under 10%, requiring plaintiffs to prove invidious discrimination, bad faith, or arbitrariness to succeed in their challenge.
Reasoning: Plaintiffs challenging a state redistricting plan with a population deviation under 10% face a presumption of constitutionality.
One Person, One Vote Principle under the Equal Protection Clausesubscribe to see similar legal issues
Application: The court evaluated the constitutionality of the population deviations in the 2013 Wake County School Board Plan and the 2015 Wake County Commissioners Plan, determining they complied with the 'one person, one vote' principle as deviations were below the 10% threshold.
Reasoning: The court has reviewed the case and determined that the population deviations in the 2013 Wake County School Board Plan and the 2015 Wake County Commissioners Plan comply with the 'one person, one vote' principle as outlined in both the United States and North Carolina Constitutions.
Plaintiffs' Burden of Proof in Redistricting Challengessubscribe to see similar legal issues
Application: The plaintiffs failed to meet their burden of proof to demonstrate that the redistricting plans were enacted with discriminatory intent or partisan bias aimed at disadvantaging specific voter groups.
Reasoning: Due to the plaintiffs' failure to meet their burden of proof, the court ruled in favor of the Wake County Board of Elections, allowing them to continue administering elections under both plans without injunction.
Racial Gerrymandering under the Equal Protection Clausesubscribe to see similar legal issues
Application: The court found no evidence of racial gerrymandering in District 4 of the 2015 Wake County Commissioners Plan, concluding that the district's creation did not subordinate traditional race-neutral principles to racial considerations.
Reasoning: Specifically, the court concluded that District 4 in the 2015 Wake County Commissioners Plan was not racially gerrymandered and did not violate the Equal Protection Clause of the Fourteenth Amendment.