Black Mississippi voters score win in battle against redistricting plan (2025)

A Reagan-appointed judge sided with Black voters in DeSoto County who claim their strength was diluted in a recent redistricting plan.

(CN) — A federal judge in Mississippi largely upheld a Voting Rights Act challenge to DeSoto County’s 2022 redistricting plan Tuesday, finding plaintiffs in the case easily demonstrated key elements of the Gingles test.

Rooted in the 1986 Supreme Court case Thornburg v. Gingles, the test is used to determine whether a voting district violates Section 2 of the VRA by diluting minority voting power. A group of Black voters filed suit against DeSoto County in September 2024, arguing the plan “severely dilutes the voting power of Black DeSoto County Mississippians and denies them a fair chance to elect representatives of their choice,” according to the complaint.

But to advance such claims under the Gingles test, Black voters had to prove three elements. First, their minority group must be large and geographically compact enough to form a majority in a single-member district. Second, their minority group must vote in a politically unified or cohesive manner. And third, the majority must vote as a bloc strongly enough to usually defeat the minority’s preferred candidates.

If all three are satisfied, the court then evaluates the “totality of circumstances” to determine if minority voters have less opportunity than others to elect representatives of their choice.

On Tuesday, Senior U.S. District Judge Glen H. Davidson found the plaintiffs “make valid allegations regarding numerosity” by claiming the Black voting age population rose from 12% to nearly 52% in the community of Horn Lake over a 20-year period. Yet, Horn Lake was separated from other nearby Black majority communities in the redistricting process and drawn into a white majority district.

To satisfy the second test regarding political cohesiveness, Davidson accepted evidence from the 2020 U.S. Senate race indicating nearly 100% of Black voters cast ballots for Mike Espy — a Black Democrat — while nearly 90% of white voters supported incumbent white Republican Senator Cindy Hyde-Smith.

“This fact, taken as true, nudges this precondition past the speculative level,” Davidson wrote.

The voters passed the third test by demonstrating that since 2018, at least 12 Black candidates have run against white candidates for county offices, but each was defeated by a white candidate. They further claimed the same was true of Black congressional and statewide candidates in the county.

“At this early stage in litigation, these allegations are enough to satisfy the third Gingles precondition,” Davidson wrote.

Looking at the totality of circumstances, Davidson found there is a history of official discrimination in Mississippi, Black voters in the county are politically cohesive and white voters vote sufficiently as a bloc to usually defeat Black-preferred candidates. He also noted racial appeals are used in campaigns, and minority-preferred candidates rarely succeed.

Davidson, an appointee of Ronald Reagan, did dismiss the voters’ claims against the county’s circuit clerk, finding there was no “causal connection” between her official duties and the plaintiffs’ injuries.

The outcome of the case will affect districts for board of supervisor elections, county judges, constables and members of the board of education and election commission in DeSoto County. The plaintiffs are represented by the NAACP Legal Defense Fund, the ACLU of Mississippi and the Harvard Election Law Clinic. Late Tuesday afternoon, LDF Special Counsel Brenda Wright provided a written statement in response to the ruling.

“The plaintiffs are glad that the Court believes their claims are meritorious enough to move forward to trial," Wright wrote. "The Black community is not fairly represented in DeSoto County government under the current redistricting plan, and we hope that this lawsuit will result in a new plan that provides a fair opportunity for Black voters to elect candidates of their choice to office.”

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