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].

After the General Assembly enacted new maps, the district court kept jurisdiction because the plaintiffs still claimed they had been sorted into districts on the basis of race^[3]. That made the case still live, not moot^[4].

The court then found four remedial districts still unconstitutional: Senate Districts 21 and 28, and House Districts 21 and 57^[5][6]. It responded by appointing a Special Master to redraw the plan, using county groupings, the Whole County Provision, compactness, and other state policy goals^[7][8].

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].