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Southeastern Geographer Vol. XXXV, No. 1, May 1995, pp. 58-74 THE PRESENT AND FUTURE OF RACIAL GERRYMANDERING: EVIDENCE FROM NORTH CAROLINA'S 12TH CONGRESSIONAL DISTRICT Gerald L. Ingalls and Toby Moore "This ... is perhaps the Negroes' temporary farewell to the American Congress. But let me say, Phoenix-like he will rise up and come again." George Henry White of Tobacco, North Carolina, 1901 North Carolina's last black US House member before 1992 (As quoted in the Charlotte Observer, 1993) In the fall of 1992, more than 90 years after the prophecy of George White, North Carolina finally did elect two black representatives to the U.S. Congress. While it took nearly 30 years of court rulings and a federal mandate in the form of the U.S. Justice Department's interpretation of Section 2 of the Voting Rights Act, voters in two newly established, black majority districts elected the state's first black man and the first black woman (actually the state's first woman, white or black) to the 103rd Congress. However, celebration of North Carolina's new minority representatives was quickly muted by an immediate challenge ofthe constitutionality ofone ofthe new minority districts—the serpentine 12th. In the summer of 1993, the United States Supreme Court stopped short of overturning, but did send back down to lower federal courts, the North Carolina Congressional Redistricting Plan, Shaw v. Reno, 113 S.Ct. 2816 (1993). What drew the attention and the measured derision of the Court was the 12th Congressional District, the result ofthe additional congressional seat afforded the state by virtue of population growth in the 1980s (Fig. 1). This district, the Court ruled, was so blatantly gerrymandered as to be "altogether antithetical to our system of representative democracy." Writing for the majority in the 5-to-4 decision, Justice O'Connor suggested North Carolina's 1992 redistricting resembled "the most egregious racial gerrymanders" and "political apartheid," Shaw v. Reno, 113 S.Ct. 2816(1993). The target of this harsh censure, the winding 12th District, was over 160 miles Dr. Ingalls is Professor of Geography and Mr. Moore is an M.A. candidate in the Department of Geography and Earth Sciences at the University ofNorth Carolina at Charlotte, Charlotte, NC 28223. Vol. XXXV, No. 1 59 Fig. 1. North Carolina's Congressional Districts. Authors' note: In Figures 1 and 2 we have taken cartographic license in reproducing the North Carolina districting plan. In reality, the 12th District is in many places only as wide as the interstate it follows, and contains numerous examples of point contiguity and " double crossovers ." long but in many spots was not much wider than the interstate (1-85) it followed. As one legislator remarked, "... if you drove down the interstate with both car doors open, you'd kill most ofthe people in the district . . ." Shaw v. Reno, S.Ct. 2816 (1993). Certainly by any spatial measure it is the most noncompact of districts (Morrill, 1981; Niemi et al., 1990), following the interstate right-of-way through the heart of the state in order to draw in black inner-city residents of some of North Carolina's more formidable urban centers—Durham, Greensboro, Winston-Salem, Gastonia, and Charlotte (Fig. 2). Countering the criticism of the 12th, the State argued that such contortions were necessary ifthey were to satisfy the demands of the Justice Department under the Voting Rights Act, suggesting the state's sizable black minority (22% in 1990) was too dispersed to be drawn into tighter districts. Table 1 summarizes the percentage of black population within each of the state's newly created 12 districts. Districts 1 and 12 comprised more than 43% of all the state's black population and in each approximately 57% of the total population was black. Whatever the outcome of the adjudication, the Court's decision has put the 12th District in the position ofbeing a major test case ofthe direction and form of the congressional redistricting which followed the 1990 Census. And this cases calls into question the future ofminority districting criteria established in another North Carolina case—Thornburg v. Gingles, 478 U.S. 30 (1986) which simultaneously set the ground rules for affirmative districting and...


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