Covington: when a redistricting remedy is federal, and when it is not
North Carolina v. Covington is a clean lesson in remedial power: a district court can keep redistricting litigation alive, but only to fix the constitutional injury it found, not to police every state-law rule along the way[1][2].
The Supreme Court affirmed that court-drawn remedy for those districts. It approved the Special Master process, including limited use of race-related data only as needed to cure the racial gerrymanders, and accepted the finding that no racial targets were sought or achieved[9][10][11].
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But the Court reversed when the district court went further and overrode the legislature’s redraw of five Wake and Mecklenburg County House districts[12][13]. Once the federal racial-gerrymander injury was cured, the federal remedy could not be used to enforce North Carolina’s ban on mid-decade redistricting[14][15].
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