Constitutional Law Keyed to Stone
Miller v. Johnson
Between 1980 and 1990, one out of ten of Georgia’s congressional districts contained a majority of black voters. The 1990 Census revealed that 27 % of Georgia’s population was black and that Georgia was entitled to an additional congressional seat. Thereupon, the Georgia General Assembly set out to redraw the State’s congressional district. In so doing, the Assembly designed an Eleventh District that combined the black neighborhoods of metropolitan Atlanta with the poor black populace of Coastal Chatham, even though these places were 260 miles apart in distance and worlds apart in culture. At trial, the District Court held that the General Assembly’s intent to racially gerrymander the Eleventh District was overwhelming. The Appellants, Miller and others (Appellants), countered that under [Shaw v. Reno] the test is not legislative intent, but whether a district is drawn so bizarrely in shape that its configuration is unexplainable other than on the basis of race.
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