Davis v. Bandemer
Davis v. Bandemer is a significant Supreme Court case concerning the issue of partisan gerrymandering, which refers to the manipulation of electoral district boundaries to favor one political party over another. In the 1980s, Indiana Democrats challenged the state's legislative reapportionment plan, alleging that it unfairly disadvantaged their party and violated the equal protection rights of Democratic voters. The Supreme Court, in a notable decision, affirmed that political parties could indeed bring equal protection claims against partisan gerrymandering, marking a critical moment in the legal landscape surrounding electoral fairness. However, the Court ultimately ruled that the level of gerrymandering in Indiana did not rise to a constitutional violation, indicating that not all apportionment plans that disadvantage a party are illegal. Importantly, the case did not involve claims of discrimination against specific racial or ethnic groups, focusing instead on the broader implications of partisan equity in elections. The decision underscored the complexities of establishing a legal standard for what constitutes unconstitutional gerrymandering while recognizing the need for evidence showing that the majority's electoral will has been persistently undermined. The outcome of Davis v. Bandemer remains a pivotal reference point in discussions about electoral integrity and representation in the political process.
Davis v. Bandemer
Date: June 30, 1986
Citation: 478 U.S. 109
Issue: Gerrymandering
Significance: The Supreme Court held that a gerrymandering scheme that benefits the dominant political party may be examined by the judiciary, serving notice to legislatures that an extreme partisan use of apportionment powers might be judged unconstitutional by the federal courts.
Indiana Democrats contended that the Republicans, who were in the majority, had sought and obtained partisan advantage in a 1981 reapportionment plan for the election of the state legislature. Irwin Bandemer and other Democrats filed suit, claiming that the scheme violated the equal protection rights of Democratic voters. By a 6-3 vote, the Supreme Court decided that the political question doctrine does not prevent a political party from making an equal protection challenge of partisan gerrymandering. By a 7-2 vote, however, the Court found that the degree of gerrymandering was not extreme enough to constitute a violation of the constitutional rights of the Democrats. Justice Byron R. White’s plurality opinion declared that an apportionment scheme that disadvantaged a political party does not necessarily violate the equal protection clause, but that plaintiffs must show evidence that the will of the majority of voters is continually frustrated. It is important to note that the plaintiffs in Bandemer did not make any allegations of discrimination against an identifiable racial or ethnic group.
