Also known as:majority-minority district · majority minority districts · majority minority district
Written by attorneys · grounded in primary & secondary sources — see below
A congressional or legislative district in which a racial minority group constitutes a numerical majority of the voting population. Such districts are drawn to enhance the group's opportunity to elect its preferred candidates. When race is the predominant factor used to draw the lines and traditional districting principles are subordinated, the plan triggers strict scrutiny under the Equal Protection Clause.
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Cases
Casebooks
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Study Supplements
How it applies
Common Examples
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Race Target Produces Irregular District
After federal officials warned that its old districts underrepresented minority voters, the State Redistricting Office instructed staff to maintain a fixed number of majority-minority congressional districts. The resulting map created District 7, which snakes around the capital region, splitting counties and cities to connect distant minority neighborhoods. Mason McCarthy and other voters in District 7 sue, alleging that race predominated over compactness and respect for political subdivisions.
Term Limits Challenge Touches Districting
State legislators propose adding term limits that would bar candidates from running in newly created majority-minority districts. Meredith Maxwell, a long-serving incumbent in one such district, argues the limits interfere with voters' ability to choose representatives in districts drawn to comply with federal voting guidelines. The court must decide whether the term-limit rule interacts with the race-conscious district boundaries.
Bizarre Shape Prompts Gerrymander Suit
The legislature draws a congressional district that winds through scattered minority neighborhoods to create a majority-minority seat. Melanie Morris and fellow residents challenge the map, claiming the serpentine boundaries can be explained only by racial considerations rather than traditional criteria. The complaint alleges that race was the predominant factor in the line drawing.
Shaw v. Reno509 U.S. 630 (1993)
Political Motive Defense Fails
Malcolm McKinley sues after the state map packs minority voters into one irregularly shaped district while splitting several counties. The legislature claims the lines were drawn to protect a safe Democratic seat. Internal documents reveal that staff were directed to hit a precise minority-population target, subordinating compactness and municipal boundaries.
Racial Target Triggers Strict Scrutiny
Mustafa Mahmoud challenges a congressional district drawn to reach a 55 percent minority population by zigzagging through minority neighborhoods and splitting established cities. The legislature defends the map as necessary to comply with federal voting guidelines. The complaint shows that the fixed racial percentage overrode contiguity and respect for political subdivisions.
Cooper v. Harris137 S. Ct. 1455 (2017)
Maximizing Districts Not Compelling
Mariam Mansour sues over four majority-minority districts created after the Justice Department objected to an earlier plan that contained only two. The new lines connect distant minority populations while ignoring compactness and county lines. Legislative records cite the goal of maximizing such districts to satisfy federal policy rather than remedying specific past discrimination.
Shaw v. Hunt517 U.S. at 905-906
Common questions
Frequently Asked
4
When does drawing a majority-minority district trigger strict scrutiny?+
Strict scrutiny applies when race is the predominant factor in drawing district lines and traditional districting principles such as compactness, contiguity, and respect for political subdivisions are subordinated. Direct evidence such as racial targets in legislative materials or circumstantial evidence such as bizarre district shapes can establish predominance. Once strict scrutiny applies, the state must show that the use of race is narrowly tailored to a compelling interest.
Supporting sources
Is maximizing the number of majority-minority districts a compelling interest?
No. Maximizing the number of majority-minority districts pursuant to a Justice Department policy is not a compelling governmental interest. Remedying the effects of identified past discrimination can qualify as compelling, but an abstract goal of increasing the number of such districts does not.
Supporting sources
How do courts determine whether race predominated in creating majority-minority districts?+
Courts examine both direct evidence such as legislative materials referencing racial targets and circumstantial evidence such as district shape, compactness scores, and whether the lines bypass nearer communities to reach minority populations. A fixed numerical minority-population goal combined with disregard for traditional criteria supports a finding of predominance.
Supporting sources
Can states still create majority-minority districts after Shaw and Miller?+
Yes, but only when race does not predominate over traditional districting principles. States may create such districts when necessary to avoid dilution of minority voting strength under the Voting Rights Act, provided the lines respect compactness, contiguity, and political subdivisions unless a compelling interest justifies the departure.
Supporting sources
voters, would the intentional creation of "
majority-minority districts
" violate the Qualifications Clauses even if it were to survive scrutiny under the Fourteenth Amendment? Cf. Shaw v. Reno , 509 U. S. 630, 649 (1993) ("[W]e express no view as to whether…
ing plan that created two
majority-minority districts
, as well as a third
district
in which African-American voters although not a
majority
made up about 35% of the voting population. The U. S. Attorney General refused to preclear the plan for…
majority-minority districts
under the Equal Protection Clause. These decisions, like Justice Powell's opinion in Bandemer , have also considered the process by which the
district
ing schemes were enacted, looked to…
Constitutional LawIndividual rights · Equal protectionUBEFoundational