In addition to identifying these essential elements of a vote dilution claim, the
Gingles Court, elaborating its analysis, made several other observations about the nature of this claim that are critical to our decision. First, emphasizing the centrality of the “size and compactness” element, the Court pointed out that where compactness cannot be shown, and where, instead, “minority voters' residences are substantially integrated throughout the jurisdiction, the at-large district cannot be blamed for the defeat of minority-supported candidates.”
Gingles, 478 U.S. at 51 n. 17, 106 S.Ct. at 2766 n. 17 (quoting Blacksher & Menafee,
From Reynolds v. Sims
to City of Mobile v. Bolden:
Have the White Suburbs Commandeered the Fifteenth Amendment?, 34 Hastings L.J. 1, 56 (1982)). Further, and of particular importance to our analysis, the Court noted that the “size and compactness” requirement confines dilution claims to situations where diminution of voting power is “proximately caused by the districting plan,”
id., and thus “
would not assure racial minorities proportional representation.”
Id. (emphasis the Court's). Finally, in defining the “essence of a
§ 2 claim,” the Court made plain that the adverse “result” for which such a claim seeks a remedy must be traceable ultimately to the impact of “a certain electoral law, practice or structure interact[ing] with social and historical conditions.”
Id. at 47.