The district court rejected each of the theories of section 2 liability advanced by the Plaintiffs.
See Magnolia Bar Ass'n v. Lee, 793 F.Supp. 1386 (S.D.Miss.1992). With regard to the Plaintiffs' straightforward challenge to the current multimember election districts, the court first determined that, in the Northern and Southern Districts, the Plaintiffs had failed to adduce evidence sufficient to satisfy the first threshold requirement of
Thornburg v. Gingles, 478 U.S. 30, 106 S.Ct. 2752, 92 L.Ed.2d 25 (1986) (i.e., they failed to demonstrate that blacks would constitute a majority of the voting age population in any of the proposed single member districts).
See 793 F.Supp. at 1401–02. The court also concluded that, in the Central District, the Plaintiffs had failed to satisfy the third
Gingles threshold requirement (i.e., they failed to demonstrate a pattern of legally significant white bloc voting).
See 793 F.Supp. at 1405–07. As for the Plaintiffs' straightforward vote fragmentation claim, the district court determined that it also failed on the first
Gingles threshold requirement. The district court specifically concluded that, even if north-south districts were drawn, blacks would not constitute a majority of the voting age population in any of the three proposed multimember districts.
See 793 F.Supp. at 1414–15. Finally, with respect to the Plaintiffs' hybrid challenge, the district court determined that, although the Plaintiffs had satisfied the
Gingles threshold requirements, their claim failed under the totality of the circumstances inquiry.
See 793 F.Supp. at 1415–18.