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Alexander v. S.C. State Conf. of the NAACP, 2024 U.S. LEXIS 2262 (S. Ct. May 23, 2024) (Alito, J.).

Judges: Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Gorsuch, Kavanaugh, and Barrett, JJ., joined, and in which Thomas, J., joined as to all but Part III-C. Thomas, J., filed an opinion concurring in part. Kagan, J., filed a dissenting opinion, in which Sotomayor and Jackson, JJ., joined.

The Constitution entrusts state legislatures with the primary responsibility for drawing congressional districts, and redistricting is an inescapably political enterprise. Legislators are almost always aware of the political ramifications of the maps they adopt, and claims that a map is unconstitutional because it was drawn to achieve a partisan end are not justiciable in federal court. Thus, as far as the Federal Constitution is concerned, a legislature may pursue partisan ends when it engages in redistricting. By contrast, if a legislature gives race a predominant role in redistricting decisions, the resulting map is subjected to strict scrutiny and may be held unconstitutional.

These doctrinal lines collide when race and partisan preference are highly correlated. We have navigated this tension by endorsing two related propositions. First, a party challenging a map’s constitutionality must disentangle race and politics if it wishes to prove that the legislature was motivated by race as opposed to partisanship. Second, in assessing a legislature’s work, we start with a presumption that the legislature acted in good faith.

In this case, which features a challenge to South Carolina’s redistricting efforts in the wake of the 2020 census, the three-judge District Court paid only lip service to these propositions. That misguided approach infected the District Court’s findings of fact, which were clearly erroneous under the appropriate legal standard. We therefore reverse the trial court in part and remand for further proceedings.

A racial-gerrymandering claim asks whether race predominated in the drawing of a district “regardless of the motivations” for the use of race. Shaw I, 509 U. S., at 645, 113 S. Ct. 2816, 125 L. Ed. 2d 511. The racial classification itself is the relevant harm in that context. A vote-dilution claim is “analytically distinct” from a racial-gerrymandering claim and follows a “different analysis.” Id., at 650, 652, 113 S. Ct. 2816, 125 L. Ed. 2d 511. A plaintiff pressing a vote-dilution claim cannot prevail simply by showing that race played a predominant role in the districting process. Rather, such a plaintiff must show that the State “enacted a particular voting scheme as a purposeful device to minimize or cancel out the voting potential of racial or ethnic minorities.” Miller, 515 U. S., at 911, 115 S. Ct. 2475, 132 L. Ed. 2d 762 (internal quotation marks omitted). In other words, the plaintiff must show that the State’s districting plan “has the purpose and effect” of diluting the minority vote. Shaw I, 509 U. S., at 649, 113 S. Ct. 2816, 125 L. Ed. 2d 511 (emphasis added).

In light of these two errors in the District Court’s analysis of the Challengers’ vote-dilution claim, a remand is appropriate.

We reverse the judgment of the District Court in part and remand the case in part for further proceedings consistent with this opinion.