Alabama State Conference of the NAACP v. Alabama

264 F. Supp. 3d 1280
CourtDistrict Court, M.D. Alabama
DecidedAugust 31, 2017
DocketCASE NO. 2:16-CV-731-WKW
StatusPublished
Cited by1 cases

This text of 264 F. Supp. 3d 1280 (Alabama State Conference of the NAACP v. Alabama) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alabama State Conference of the NAACP v. Alabama, 264 F. Supp. 3d 1280 (M.D. Ala. 2017).

Opinion

MEMORANDUM OPINION AND ORDER

W. Keith Watkins, CHIEF UNITED STATES DISTRICT JUDGE

I.INTRODUCTION & FACTUAL BACKGROUND

The state of Alabama selects appellate judges using at-large elections. This means that every Alabamian eligible to vote can do so with respect to every seat on the state appellate courts, regardless of residence, as opposed to having their votes limited by geography—as is the case, for example, in the state’s legislative elections. In Alabama, African-American voters make up about 26% of the population, yet they rarely are elected to any of the 19 Alabama appellate court seats. According to Plaintiffs’ complaint, only two African-American candidates ever have won an at-large election in the state of Alabama, and both were first appointed by the Governor. No African-American candidate has won an at-large election without a preceding gubernatorial appointment. (Doc. # 1, at 7.)

Plaintiffs, the Alabama State Conference of the National Association for the Advancement of Colored People (“NAACP”) and four black Alabama voters, claim this election practice unfairly dilutes the black vote, which has the effect of denying African-American voters an equal opportunity to participate in the political process, thereby violating Section 2 of the Voting Rights Act (“VRA”), 52 U.S.C. § 10301 (“Section 2”). They bring this claim for declaratory and injunctive relief, asking the court to strike down Alabama’s at-large election system for appellate judges and order the state to implement a new election method consisting of single-member districts. Defendants, the State of Alabama and the Alabama Secretary of State John Merrill (in his official capacity), moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. upon which relief can be granted. (Doc. # 17.) For the reasons set forth below, the motion is due to be denied.

II. JURISDICTION & VENUE

The court has subject-matter jurisdiction under 28 U.S.C. § 1331 because this action is brought under the VRA. The parties do not contest personal jurisdiction or venue;

III. STANDARD OF REVIEW

To survive a motion to dismiss under Rule 12(b)(6), a- complaint must include [1284]*1284“enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007). A “claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is hable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009). While the standard does not require “detailed factual allegations,” a complaint will not survive by tendering “naked assertion[s] devoid of further factual enhancement” or “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Id. (quoting Twombly, 550 U.S. at 555, 127 S.Ct. 1955) (quotation marks omitted). “When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. at 679, 129 S.Ct. 1937.

IV. DISCUSSION

Section 2 of the VRA “outlaws election practices that result in racial discrimination.” 1 Nipper v. Smith, 39 F.3d 1494, 1509-10 (11th Cir. 1994). One way an election practice may violate Section 2 is by diluting the vote of minority groups. See Thornburg v. Gingles, 478 U.S. 30, 48-51, 106 S.Ct. 2752, 92 L.Ed.2d 25 (1986) (discussing at length Section 2 claims based on vote dilution); see also Allen v. State Bd. of Elections, 393 U.S. 544, 569, 89 S.Ct. 817, 22 L.Ed.2d 1 (1969) (“The right to vote can be affected by a dilution of voting power as well as by an absolute prohibition on casting a ballot.”). State judicial elections fall within the ambit of Section 2. Chisom v. Roemer, 501 U.S. 380, 404, 111 S.Ct. 2354, 115 L.Ed.2d 348 (1991).

To establish a vote dilution claim under Section 2, plaintiffs challenging an at-large election system on behalf of a protected class of citizens must show that (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,” and (3) the majority group “votes sufficiently as a bloc to enable it ... usually to defeat the minority’s preferred candidate.” Gingles, 478 U.S. at 49-51, 106 S.Ct. 2752. In the Eleventh Circuit, satisfaction of the first factor also requires showing “the existence of a proper remedy.” Davis v. Chiles, 139 F.3d 1414, 1419 (11th Cir. 1998) (noting in footnote 14 that “[o]ur en banc court established this principle as part of our Section Two jurisprudence in our interpretation of the first Gingles factor in Nipper"); see Nipper, 39 F.3d at 1530-31 (holding that the first Gingles factor “dictates that the issue of remedy is part of the plaintiffs prima facie case in section 2 vote dilution cases”).

The Gingles factors, however, represent only the preconditions for demonstrating vote dilution—they are “necessary, but not always sufficient, to establish a claim for relief.” Nipper, 39 F.3d at 1512. The other half of the analysis is heavily dependent on the facts of the case. See Johnson v. De Grandy, 512 U.S. 997, 1020-21, 114 S.Ct. 2647, 129 L.Ed.2d 775 (1994) (“No single statistic provides courts with a shortcut to determine whether [an election structure] unlawfully dilutes minority voting strength.”); Nipper, 39 F.3d at 1498 (declaring that Section 2 vote dilution cases “are inherently fact-intensive”); id. at 1527 (“Courts evaluating vote dilution claims ... must consider all relevant evidence”). Once the factors are met, Sec[1285]*1285tion 2 demands the court inquire whether, “under the totality of the circumstances,” the members of the minority group “possess the same opportunities to participate in the political process and elect representatives of their choice enjoyed by other voters.”2 Id. at 1512 (quoting League of United Latin Am. Citizens, Council No. 4434 v. Clements, 999 F.2d 831, 849 (5th Cir. 1993)); see also Chisom, 501 U.S. at 399, 111 S.Ct. 2354 (1991) (rejecting the argument that the word “representative” in Section 2 excluded elected judges). Such an inquiry necessitates a “comprehensive, not limited, canvassing of relevant facts.” Johnson, 512 U.S. at 1011, 114 S.Ct. 2647.

Defendants’ motion to dismiss attacks Plaintiffs’ Section 2 claim on three fronts.

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Bluebook (online)
264 F. Supp. 3d 1280, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alabama-state-conference-of-the-naacp-v-alabama-almd-2017.