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    Georgia State Conference of the NAACP v. Georgia

    On April 24, 2017, the Georgia State Conference of the NAACP filed a lawsuit alleging that Georgia’s 2015 state house map was drawn with discriminatory purpose in violation of the Constitution and Voting Rights Act. In addition, the plaintiffs assert that the map resulted in unconstitutional racial and partisan gerrymanders.

    Published: January 15, 2019

    Note: The Brennan Center is not a participant in this case.

    Case Background

    The Georgia State Conference of the NAACP is challenging two districts in the 2015 state house plan, which is the product of a mid-decade redistricting by Republican lawmakers. The plaintiffs claim Republicans used race as a means for “achieving [a] partisan end” when they redrew the map to protect white Republican incumbents and deny African-American voters an equal opportunity to elect their candidates of choice.

    The plaintiffs are asking a three-judge panel to declare that the two challenged districts violate the Constitution and Voting Rights Act, order them redrawn, and impose preclearance requirements on Georgia for the next ten years under section 3 of Voting Rights Act.

    The state filed a partial motion to dismiss, arguing, among other things, that the plaintiffs’ claims under Section 2 of the Voting Rights Act and the Fourteenth Amendment lack factual allegations that could show discriminatory effect. The state also disputed the plaintiffs’ reliance on the three-part test from Whitford v. Gill for their partisan gerrymandering claim, arguing that the plaintiffs have not shown that the test—which was originally developed to respond to a state-wide gerrymandering challenge—is reliable or appropriate for challenges to single-districts.

    On August 25, the court entered an order dismissing the plaintiffs’ section 2 and partisan gerrymandering claims. The order did not address the plaintiffs’ racial gerrymandering claims which remain pending.

    After the court consolidated this case with Thompson v. Crittenden, the court ordered discovery to begin on the racial gerrymandering claims. On March 9, discovery relating to the racial gerrymandering claims concluded. Discovery on the remaining section 2 claims will conclude on October 12. 

    On June 1, the court denied the plaintiffs’ request for a preliminary injunction.

    On September 4, 2018, the court granted the plaintiffs’ request to amend their complaint to include partisan gerrymandering claims. 

    On January 15, 2019, the court granted the parties’ joint motion to dismiss the case without prejudice.

    Documents

    District Court