Covington: when a redistricting remedy is federal, and when it is not

In North Carolina v. Covington, the Supreme Court upheld a district court’s redrawing of districts still found to be unconstitutional racial gerrymanders. The court could use race-related data only as needed to remedy that constitutional injury. But after the injury was cured, the federal court could not use its remedy to enforce North Carolina’s ban on mid-decade redistricting. Its power extended to fixing the federal violation, not policing state-law rules.

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