6
LOUISIANA v. CALLAIS
Opinion of the Court
involved a “vote dilution” claim, i.e., a claim that a districting scheme impermissibly lessens the weight of the votes of
minority voters.
In White, the Court affirmed a judgment that Texas had
used two multimember electoral districts “invidiously to
cancel out or minimize the voting strength of racial groups.”
Id., at 765. According to White, a vote-dilution plaintiff had
to show that “the political processes leading to nomination
and election were not equally open to participation by the
group in question—that its members had less opportunity
than did other residents in the district to participate in the
political processes and to elect legislators of their choice.”
Id., at 766.
The decision in White did not say anything one way or
another about proof of discriminatory purpose or intent, but
the Court’s rationale rested on evidence that gave rise to an
obvious inference that the State had set out to prevent the
election of candidates preferred by minority voters. The
Texas districting scheme generally used single-member districts but employed multimember districts in two parts of
the State where single-member districts might have resulted in the election of minority candidates. The Court observed that the use of multimember districts is not “necessarily” or “per se” unconstitutional, but it recognized that
such districts can be employed to achieve discriminatory
ends. Id., at 765; see also Perkins v. Matthews, 400 U. S.
379, 389 (1971) (observing that a switch to at-large elections could be a “metho[d] to maintain white control of the
political process”); Allen v. State Bd. of Elections, 393 U. S.
544, 569 (1969) (explaining that a change to at-large voting
could nullify the ability of minority voters to elect their candidate of choice). The Court also cited strong evidence that
the legislature had done so in the case at hand. Writing at
a time when the Democratic Party was dominant in much
of Texas, the Court noted that a “white-dominated organization,” which had “effective control” over candidate slating