11th Circuit Finds Georgia County's Redrawn School Districts Dilute Voting Power of Black Residents

By Laura Temme, Esq. on October 30, 2020 | Last updated on August 10, 2021

The redrawing of school board districts in Georgia's Sumter County violated the Voting Rights Act of 1965 by diluting Black residents' voting power, according to a recent decision by the Eleventh Circuit Court of Appeals. This decision is the latest in a six-year legal battle that has bounced back and forth between the court of appeals and the district courts.

Six Years In the Courts

In 2014, a new law in Georgia reduced the size of Sumter County's school board from nine members to seven. Of those, five would be elected from single-member districts. The other two would be "at-large" seats.

The redistricting eliminated seats that were generally held by Black board members and created two that Black candidates were unlikely to win. It also packed most of the county's Black voters into two of the five single-member districts. Before the creation of the new map, the Sumter County School Board was predominantly Black. After, only two seats were held by Black residents.

Mathis Kearse Wright Jr., a local reverend, challenged the redistricting. He claimed the new school district map created an electoral mechanism that diluted the strength of Sumter County's Black voters. The district court agreed.

What followed was a lot of back and forth between the district court and the Eleventh Circuit. In January 2020, the district court entered a remedial order that drew a new map with seven single-member districts. The at-large seats were removed.

11th Circuit Supports New Map

On appeal by the Sumter County Board of Elections and Registration, the Eleventh Circuit affirmed the new map drawn by the district court - holding once again that the redistricting plan violated the Voting Rights Act.

A successful claim under Section 2 of the Voting Rights Act must show that, based on the totality of the circumstances, the political process is not equally open to participation by members of a protected class, such as race. Someone alleging vote dilution must satisfy three factors:

  1. The minority group is "sufficiently large and geographically compact to constitute a majority in a single-member district"
  2. The minority group is "politically cohesive"
  3. Sufficient racial bloc voting exists such that the white majority usually defeats the minority's preferred candidate

The district court found, and the Eleventh Circuit affirmed, that these factors were present in Sumter County after the districts were redrawn in 2014. Experts agreed that elections in Sumter County were highly polarized racially and that candidates Black voters preferred had more difficulty getting elected. The evidence also showed that there were enough Black residents of Sumter County to form a majority in at least one more single-member district.

The 2020 election is set to be the most heavily litigated in history. But in Sumter County, the fight against voter suppression has raged on for more than six years. Will this decision finally be the end? Stay tuned.

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