Hays v. State of Louisiana

SHAW, Chief District Judge,

concurring:

I concur in the able opinion of the majority. It is an honest effort to provide a suitable plan for Congressional districts in Louisiana within the restraints of the Constitution. I would, however, like to add a few words which may be somewhat repetitive but which address matters in our December 28, 1993 ruling which we have adopted by reference as well as additional findings supported by the evidence. Applying the same constitutional analysis to Act 1 has led us to a similar conclusion.

Again, this Court is called upon to answer the same question, “Does a state have the right to create a second racial majority-minority Congressional district by racial gerrymandering?”

The United States Supreme Court has answered that question for this Court in Shaw v. Reno,1 “Yes, but only if the plan is narrowly tailored to further a compelling state interest.”

For the following reasons, this Court finds that the Congressional Redistricting Plan embodied in Act 1 and District 4, in particular, is the product of racial gerrymandering and is not narrowly tailored to further any compelling governmental interests. The plaintiffs’ right to equal protection as guaranteed by the United States Constitution is violated by this redistricting plan, and as such, the plan is null and void.

Racial Gerrymandering

As stated in our previous opinion, racial gerrymandering is defined as the intentional *126segregation of voters on the basis of race. This Court is called upon to first determine whether the redistrieting plan is the result of racial gerrymandering.

At trial, the witnesses for the State readily admitted that the purpose of District 4 was to create a second black majority district. The testimony of the state legislators and the State Senate Assistant Secretary confirmed that the district lines were driven by the fact that the black population in the State of Louisiana was sufficiently dispersed through the State that it was impossible to create a second majority black district without skewing the lines into a long irregular shape, as demonstrated by District 4 of the plan.

The districting plan embodied in Act 1 is highly irregular in its shape. Though it may be less bizarre than the plan created in Act 42, the physiognomy of District 4 still strongly suggests that the Legislature engaged in racial gerrymandering in creating the district. Looking at District 4 on a map of Louisiana, it appears as if someone knocked over an inkwell somewhere around Waskom, Texas, spilling ink aimlessly across the map of Louisiana. There is simply nothing regular about the contours of District 4.

This Court acknowledges that the appearance or beauty of a district is irrelevant to a constitutional analysis; however, the irregularity in shape of a district is suspect and can indicate racial gerrymandering.

Although Shaw discusses the concept of bizarre or irregular shape as a means of demonstrating or inferring racial gerrymandering, the high court in no way indicated that shape alone was a determining factor in a finding of racial gerrymandering.

This Court finds, aside from the irregularity of the shape of this district, the evidence at trial clearly supported a finding of racial gerrymandering. The Louisiana Legislature abandoned traditional districting principles to arrive at a Plan which created two majority black voting districts. Act 1, like Act 42, completely disregards the traditional districting principles of compactness, respect for political subdivisions, and respect for commonality of interests.

a. Compactness

District 4, under Act 1, begins in Caddo Parish, and includes the Parishes of DeSoto, Red River, Sabine, and Natchitoches, all located in clearly defined North Louisiana, and ends in Ascension Parish, after cutting through the French region of Louisiana called “Aeadiana,” which includes Lafayette, St. Martin, St. Landry, and Evangeline Parishes. The district is approximately 250 miles long, and meanders through 15 parishes, making it considerably longer than any other district in the State. District 4 cuts up four major population centers of Louisiana, including Shreveport, Alexandria, Lafayette, and Baton Rouge, in its efforts to capture sufficient pockets of African-American voters, paying no respect to parish lines.2 The district points fingers out into Caddo, Rap-ides, and Lafayette Parishes, while taking small bites out of St. Martin and Iberville Parishes. A district that stretches over as much territory, touching so many media and population centers, cannot be said to be compact.

b. Respect for Political Subdivisions

Although Act 1 is an improvement from Act 42, the state legislature continues to disregard the parish lines in fashioning a plan to create a second minority district.

In the creation of District 4, the State found it necessary to fragment twelve of the fifteen parishes comprising District 4, splitting sixteen parishes statewide under the plan. District 4 is made up of pieces and parts of twelve parishes and splits four of the State’s largest cities, outside of New Orleans — Shreveport, Baton Rouge, Lafayette, and Alexandria. Clearly, Act 1 has no respect for Louisiana’s political subdivisions.

c. Commonality of Interests

To say that District 4 comprises voters with common interests violates all traditional *127north-south, ethno-religious, economic and historical distinctions in Louisiana which created this State’s diverse personality.

District 4 includes North Louisiana Enghsh-Scoteh-Irish, mainline Protestants, South Louisiana French-Spanish-German Roman Catholics, traditional rural black Protestants, and Creoles. The district encompasses North, Central, and South Louisiana, each of which has its own unique identity, interests, culture, and history. The agricultural regions of District 4 include cotton, soybean, rice, sugar cane, and timber. Such diverse agricultural constituency have few common interests. We continue to question how one Congressional representative could adequately represent the varying interests of residents in such far-flung areas of the State.

A district which disregards commonality of interests and stretches across the State in a haphazard manner without regard to political subdivisions can only be explained as the result of racial gerrymandering.

Justification for Defendant’s Plan

The State attempted to put forth a race-neutral explanation for its plan by the use of a geographer who testified that District 4 was drawn along the Red River Valley demonstrating a commonality of interest. The State failed in its burden of proof to show that the Red River Valley region in the State of Louisiana demonstrated a commonality of interests.

Secondly, the State offered as support for its plan, that District 4 of the plan was modeled after the old eighth district in Louisiana which was created for and represented by Congressman Gillis Long.

This Court is not swayed by the assertion that the tradition of the past regarding the old eighth district is binding on this Court, due to the fact that the old eighth district was never challenged on constitutionality by any court in the United States. This Court is not called upon to determine the constitutionality of the old eighth district, and does not rely on the fact that such a district existed in Louisiana. What was done by the Louisiana Legislature in the old eighth has no application to this ease before this Court, and cannot be used as a comparable for the plan before this Court.

Accordingly, this Court finds that the only explanation of the State’s Redistrieting Plan was racial gerrymandering. The State intentionally segregated voters into Congressional districts on the basis of race, in order to intentionally create a second black majority voting district.

Narrowly Tailored

A racially gerrymandered plan is subject to strict scrutiny, and as such it violates the Equal Protection Clause of the Fourteenth Amendment unless it is narrowly tailored to further a compelling governmental interest.

Compelling Governmental Interest

Again, the State advances two possible compelling state interests to justify their racial gerrymandering: (1) compliance with the Voting Rights Act, and (2) remedying the effects of past discrimination.

a. Compliance with the Voting Rights Act

Section 5 of the Voting Rights Act provides that a state has an affirmative duty to avoid retrogression or to avoid enactment of a plan that has the purpose or effect of denying or abridging the right to vote on account of race.

The defendants established that the Louisiana Legislature was operating under the belief that a second majority-black district was mandated by the Department of Justice to avoid retrogression, and obtain preclearance. Without commenting further regarding the role of the Department of Justice in affecting the plan enacted in Act 1, this Court finds no evidence to support a finding that a second majority-black district is required by Section 5 of the Voting Rights Act, to avoid retrogression. Prior to the census, Louisiana’s Congressional delegation had only one black representative out of eight congressmen. Certainly, one congressman out of seven cannot constitute retrogression. Section 5 of the Voting Rights Act does not constitute a compelling governmental interest in this case.

*128Additionally, Section 2 of the Voting Rights Act prohibits a plan that has the effect of diminishing or abridging the voting strength of a protected class. However, this claim must fall in the face of the Supreme Court’s ruling in Thornburg v. Gingles.3

This Court finds that Section 2 of the Voting Rights Act is not implicated by this plan. Although the Voting Rights Act would permit a second minority district, such a district is not compelled by the Act.

b. Remedy Past Discrimination

The State advanced, as justification for its racially gerrymandered district, the belief that the creation of a second minority district in Louisiana is mandated to remedy the past discrimination which has existed in Louisiana.

This Court struggled with the concept of how to define “past discrimination” in Louisiana. Certainly, the history of Louisiana, as of most states in the deep South with respect to its treatment of blacks, is indelibly imprinted in our memories. This State, having inflicted great atrocities against minorities, has made great strides in remedying past discrimination, being ever vigilant of its current existence in the attitudes of many of its residents today. Louisiana, in the sense of its history, will always have a history of past discrimination. However, this Court must determine whether this State has a history of past legal discrimination in the voting laws and procedures which compels it to make reparations and remediation.

The Civil Rights Act of 1964 and the Voting Rights Act of 1965 have mandated the elimination of obstacles to minority participation at the polls. Since those turbulent times in Louisiana, and through the efforts of many black and white leaders in this State, we have seen the elimination of poll taxes, literacy tests, and violence to reduce or prohibit African-American participation in our elections process. Louisiana has minority representation in nearly every level of government, in almost every area of the State. Speaking only in the sense of the voting rights of minorities in Louisiana, this Court finds that there exist no significant obstacles for minorities in this State to participate in the elections process which have not been remedied by the Civil Rights Act of 1964 and the Voting Rights Act of 1965. Accordingly, the concept of remedying past discrimination is not a compelling governmental interest in the recent history of Louisiana in the area of voting rights.

This Court acknowledges the great benefits that are derived by an increase in minority representation in government, not only for those who are represented but also to the process of government itself. Given the opportunity to serve, minorities have shown that they perform admirably. A greater number of African-American leaders in the government process not only provide positive role models for all black citizens, but their efforts in government will insure that the legal obstacles to minority advancement in all areas of life will be eliminated. However, to disregard the rights of all citizens of the State of Louisiana would violate the Equal Protection Clause of the United States Constitution, and such a plan would do further violence to the ultimate goal of a colorblind system.

Although we found that the evidence presented at the hearing did not support the contention that the Legislature was operating pursuant to a compelling state interest, even if there had been satisfactory evidence at trial that there is a compelling state interest in creating a second majority-minority Congressional district, the plan embodied by Act 1 was not narrowly tailored to effect that interest. The fact that outside of the Orleans Parish area, the minority black population is relatively dispersed throughout the rest of the State, elicited the question of whether it was even possible to develop a districting plan that creates a second majority-minority district and is narrowly tailored, in the sense that the plan in total does not unduly burden the rights of third parties.

The Court Imposed Plan

This Court, with the assistance and guidance of our appointed special master, devised *129a Congressional Districting Plan. This plan was created from a computer program which included the demographics of the State of Louisiana. This Court started with the goal of creating seven Congressional districts, remaining true to the “one man, one vote” requirement, and the constraints of Shaw and Gingles.

After considering every combination available, this Court reached the conclusion that the diffused population of black voters in Louisiana, outside of District 2, makes it impossible to draw a Congressional plan which contains two minority-majority districts and passes constitutional muster. Act 1 clearly does not.

Conclusion

While this Court finds that the creation of a second minority-majority district in Louisiana is permissive and advantageous, we do not find it compelling, under the constraints of the Constitution.

This Court applauds the Louisiana Legislature in its efforts to create a second minority district; however, such efforts run aground of the Constitution and the dictates of Shaw v. Reno.

. 508 U.S. -, 113 S.Ct. 2816, 125 L.Ed.2d 511 (1993).

. This court notes that District 4 covers, not only four major population centers of Louisiana, but includes four separate and major media centers of this state. Congressional candidates would be required to spend substantial amounts of money and time covering the voters in four major areas of the state.

. 478 U.S. 30, 106 S.Ct. 2752, 92 L.Ed.2d 25 (1986).