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In the 1996 case of Lucious Abrams, Jr., G. L. Avery, William Gary Chambers Sr., and Karen Watson v. Davida Johnson et al., the plaintiffs were four African-American voters from Louisiana who challenged a redistricting plan for electing judges to state courts in Baton Rouge on grounds that it violated Section 2 of the Voting Rights Act by diluting minority voting strength. The Supreme Court ruled against them, finding no violation because they failed to demonstrate that under an alternative plan they would have been able to elect their preferred candidates without relying on crossover votes from white majority voters - a requirement established by precedent cases such as Thornburg v Gingles (1986). This decision reaffirmed that racial gerrymandering claims require proof not just of racially polarized voting but also sufficient minority population size and geographical compactness to constitute a majority in some single-member district.
The dissenting opinion in the case of Abrams et al. v. Johnson et al., argued that the majority's decision to uphold Georgia's redistricting plan was incorrect and inconsistent with previous rulings on racial gerrymandering. The dissenters believed that race was used as a predominant factor in drawing district lines, which is unconstitutional according to prior Supreme Court decisions such as Shaw v. Reno (1993). They also disagreed with the majority’s assertion that there were compelling state interests justifying this use of race, arguing instead that these supposed interests were not sufficiently related to remedying past discrimination or ensuring minority representation under Section 5 of the Voting Rights Act. Furthermore, they contended that even if these interests could be considered legitimate, they did not justify an extreme deviation from traditional districting principles like compactness and respect for political subdivisions.