Alexander v. S.C. State Conference NAACP

Because race and partisan affiliation are highly correlated in this context, the Court applied a presumption favoring partisan motives and required plaintiffs to disprove South Carolina's race-neutral explanation for removing Black voters from District 1 with clear evidence of racial predominance. The district court's finding of racial predominance was clearly erroneous because plaintiffs failed to adequately rebut the legislature's articulated partisan justification despite the substantial movement of approximately 30,000 Black voters. Under the applicable burden-shifting framework, the existence of a plausible partisan explanation was sufficient to defeat the racial gerrymandering claim when plaintiffs could not demonstrate that race, not partisanship, was the predominant motivating factor. The map therefore stood because plaintiffs had not met their burden under the presumption favoring partisan explanations when race and partisanship align.