Editing Easley v. Cromartie

{{Short description|2001 US Supreme Court gerrymandering case}}
{{Use mdy dates|date=August 2023}}
{{Infobox SCOTUS case
  | Litigants               = Easley v. Cromartie (also known as Hunt v. Cromartie)
  | ArgueDate               = November 27
  | ArgueYear               = 2000
  | DecideDate              = April 18
  | DecideYear              = 2001
  | FullName                = Michael F. Easley, Governor of North Carolina v. Martin Cromartie, et al.
  | USVol                   = 532
  | USPage                  = 234
  | ParallelCitations       = 121 S. Ct. 1452; 149 [[L. Ed. 2d]] 430
  | Prior                   = {{ussc|name=Shaw v. Reno|volume=509|page=630|pin=|year=1993}}; on remand, ''Shaw v. Hunt'', 861 [[F. Supp.]] [https://law.justia.com/cases/federal/district-courts/FSupp/861/408/2261731/ 408] ([[E.D.N.C.]] 1994); reversed, ''[[Shaw v. Hunt]]'', {{ussc|517|899|1996}}; on remand, ''Cromartie v. Hunt'', 34 [[F. Supp. 2d]] [https://law.justia.com/cases/federal/district-courts/FSupp2/34/1029/2462399/ 1029]; (E.D.N.C. 1998); reversed, {{ussc|name=Hunt v. Cromartie|526|541|1999}}; on remand, ''Cromartie v. Hunt'', 133 [[F. Supp. 2d]] [https://law.justia.com/cases/federal/district-courts/FSupp2/133/407/2292720/ 407] (E.D.N.C. 2000)
  | Subsequent              = 
  | Holding                 = The District Court's conclusion that the State violated the Equal Protection Clause in drawing the 1997 boundaries was based on clearly erroneous findings.
  | Majority                = Breyer
  | JoinMajority            = Stevens, O'Connor, Souter, Ginsburg
  | Dissent                 = Thomas
  | JoinDissent             = Rehnquist, Scalia, Kennedy
  | LawsApplied             = 
}}

'''''Easley v. Cromartie''''', 532 U.S. 234 (2001), is an appeal of the [[Supreme Court of the United States|United States Supreme Court]] case ''[[Hunt v. Cromartie]]''. The case defendant is [[Mike Easley]], who became North Carolina governor following [[Jim Hunt]]. The court's ruling on April 18, 2001, stated that redistricting for political reasons did not violate Federal [[Civil Rights]] Law banning race-based [[gerrymandering]]. (Case No. 99-1864).

The issue facing this Supreme Court case was Constitutional validity of the [[List of United States congressional districts|Congressional Districts]] in [[North Carolina]].  Specifically, the 12th district which cut through the [https://www.atlasobscura.com/places/north-carolinas-12th-congressional-district southwestern portion] of the state.  The complaint of the plaintiff and North Carolina citizens was that the drawing of the district violated the [[Equal Protection Clause]] of the Constitution as the district was drawn primarily amongst racial considerations.<ref name=":0">{{Cite web|url=http://www.lawschoolcasebriefs.net/2013/11/easley-v-cromartie-case-brief.html|title=Easley v. Cromartie case brief|last=LawSchoolCaseBriefs.net|access-date=2019-03-05}}</ref>

The justification of the court stated that in North Carolina, race and politics are strongly correlated.  The district may be majority African American, however, Southern Blacks have strong tendencies to vote [[Democratic Party (United States)|Democrat.]]<ref name=":0" /> Voter registrations were used as evidence to prove to the court that the redistricting which drew the 12th district were arguably based on political reasons.<ref name=":1">{{Cite web|url=https://supreme.justia.com/cases/federal/us/532/234/|title=Easley v. Cromartie, 532 U.S. 234 (2001)|website=Justia Law|language=en|access-date=2019-03-05}}</ref> In the majority opinion, [[Stephen Breyer|Stephen G Breyer]] says "the party attacking the legislatively drawn boundaries must show at the least that the legislature could have achieved its legitimate political objectives in alternative ways that are comparably consistent with traditional districting principles", and in this case, the plaintiffs were not able to make this argument compelling.<ref name=":1" />

Justice [[Sandra Day O'Connor|O'Connor]] previously sided with the district courts in ''[[Hunt v. Cromartie|Hunt v Cromartie]],'' however, this instance ruled with the North Carolina legislature, acting as the all important swing vote to overturn the previous decision 5–4.  The allegedly odd-shaped district was allowed to stand.

==See also==
* ''[[Shaw v. Reno]]'', {{ussc|509|630|1993}}
* ''[[Hunt v. Cromartie]]'', {{ussc|526|541|1999}}
* [[List of United States Supreme Court cases, volume 532]]

==References ==
{{Reflist}}

==Further reading==
*{{cite journal |last=Kravetz |first=R. F. |year=2001 |title=That the District Will Be Held to Be an Unconstitutional Racial Gerrymander: ''Easley v. Cromartie'' |journal=Duquesne Law Review |volume=40 |pages=561 |issn=0093-3058 }}
*{{cite journal |last=Warren |first=C. G. |year=2001 |title=Towards Proportional Representation? The Strange Bedfellows of Racial Gerrymandering and Equal Protection in ''Easley v. Cromartie'' |journal=Mercer Law Review |volume=53 |pages=945 |issn=0025-987X }}

==External links==
* {{caselaw source
 | case = ''Easley v. Cromartie'', {{ussc|532|234|2001|el=no}}
 | googlescholar = https://scholar.google.com/scholar_case?case=172627255846891648
 | justia =https://supreme.justia.com/cases/federal/us/532/234/
 | loc =http://cdn.loc.gov/service/ll/usrep/usrep532/usrep532234/usrep532234.pdf
 | oyez =https://www.oyez.org/cases/2000/99-1864
 }}

{{USRedistrictinglaw}}
{{North Carolina}}

[[Category:United States Supreme Court cases of the Rehnquist Court]]
[[Category:United States electoral redistricting case law]]
[[Category:2001 in United States case law]]
[[Category:Congressional districts of North Carolina]]
[[Category:Legal history of North Carolina]]
[[Category:2001 in North Carolina]]
[[Category:United States Supreme Court cases]]

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