City of Hammond, Indiana v. Lake County Board of Elections

The City of Hammond and three voters filed a lawsuit against the state alleging that Indiana’s use of a hybrid, merit-based judicial selection process violated the section 2 of the Voting Rights Act. The lawsuit alleged that the state selection system, also known as the “Missouri Plan,” gives minority voters less opportunity than other members of the electorate. The district court dismissed the lawsuit and plaintiffs appealed. The Seventh Circuit affirmed, explaining that recent Supreme Court precedent clarified that section 2 imposes liability only when the circumstances give rise to a strong inference that intentional discrimination occurred and that no inference was possible under the facts of the case. (ST. EVE and LEE, concurring)