Miller v. Johnson: Drawing the Line on Racial Gerrymandering
Doak, Darin R.
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By rejecting the Georgia State Legislature's attempt to redraw its political districts to ensure election of black representatives, the Supreme Court in Miller v. Johnson exposed a fallacy that served as the foundation for eighteenth-, nineteenth-, and twentieth-century barriers to minority franchise rights: the idea that minority groups act and vote similarly. Treading lightly through the political thicket of redistricting, the Miller Court eliminated this threat by prohibiting political districts drawn with substantial reliance upon race. This article discusses the merits of the Miller decision and its place in the evolution of minority voting rights. The article also suggests that the Miller Court should have extended its decision to prohibit political as well as racial gerrymandering. Nonetheless, the article concludes that the Court's eradication of racial gerrymandering has finally answered the cry of civil rights activists for total equality.