Abrams v. Johnson

The census performed in 1990 revealed that Georgia's population had increased significantly, and that Georgia was entitled to 11, instead of 10, congressional seats. Under the Voting Rights Act of 1965, it was the responsibility of the Georgia state legislature to reapportion its congressional seats. However, the legislature was required to have its plan approved by either the U.S. Department of Justice, or by a federal district court. In order to secure the approval of the Department of Justice, the Georgia legislature eventually adopted a plan which contained three districts known as "majority-minority" districts. "Majority-minority" districts are districts in which a majority of the registered voters are members of racial minorities. These districts are designed to make it easier for minority candidates to get elected, and thus increase minority representation in Congress.

In this case, the legislature's plan created three (out of 11) districts in which a majority of the registered voters were African American. However, one such district was oddly shaped, being very long and narrow, connecting distant cities to achieve a majority of African Americans. In the 1995 case Miller v. Johnson, the Supreme Court found that this redistricting plan was unconstitutional because race was a predominate factor in the designing of the Georgia legislature's plan. The Court found that race was a predominate factor based on the bizarre shape of the districts and other evidence of the Georgia legislature's intention to create three majority-minority districts. The Court concluded that race may not be used as a basis for redrawing congressional districts, even if it is used for the beneficial purpose of increasing minority representation. Following the Court's decision in the Miller case, the Georgia legislature was unable to agree on another plan. Accordingly, under the Voting Rights Act, a three-judge panel of the U.S. District Court for the Southern District of Georgia devised its own plan. This plan included only one majority-minority district.