McCoy v. Chicago Heights Election Commission

Federal 7th Circuit Court
Civil Court
Election Law
Citation
Case Number: 
No. 16-3463
Decision Date: 
January 22, 2018
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in approving as constitutional defendant-City’s proposed reapportionment map of aldermanic districts within City, where said map was drafted in response to 2010 consent decree that had been entered after finding that prior map had diluted voting opportunities based on race. While equal protection clause requires that officials be elected from voting districts that had substantially equal populations that had less than ten percent deviation from each other, City’s justification for instant overall 12 percent deviation was legitimate, where City explained that proposed map: (1) had goal of changing existing wards as little as possible; (2) used natural boundaries of major thoroughfares as dividing lines; and (3) increased ward’s compactness and eased voter confusion that had existed in prior map. Also, plaintiffs failed to present evidence that City employed any discriminatory criteria in its proposed map. Ct. further rejected plaintiffs’ argument that they had right to submit alternative map to Dist. Ct. for its consideration, since City had sole responsibility under consent decree to reapportion ward map, and City otherwise provided plaintiffs opportunity to submit input to proposed map.