The U.S. Supreme Court case Michael F. Easley, Governor of North Carolina, et al. v. Martin Cromartie, et al., 2000 revolved around the issue of racial gerrymandering in North Carolina's 12th Congressional District after the 1990 census. The district was redrawn several times due to legal challenges alleging that race had been improperly used as a predominant factor in its design which violated equal protection principles under the Fourteenth Amendment. In this particular instance, plaintiffs argued that even though there were nonracial explanations for why voters were moved into and out of the district during redistricting (like political affiliation), it was still racially motivated because African Americans overwhelmingly vote Democratic. However, on appeal from a three-judge panel decision favoring plaintiffs at District Court level, the Supreme Court reversed by a 5-4 majority ruling stating that summary judgment should not have been granted to plaintiffs since they failed to demonstrate sufficient evidence showing race rather than politics predominantly explained North Carolina’s latest plan.

In the dissenting opinion for Easley v. Cromartie, Justice Thomas argued that the majority had misapplied previous Supreme Court rulings on racial gerrymandering and failed to properly consider evidence suggesting race was a predominant factor in redistricting. He criticized the majority's reliance on circumstantial evidence of political motivations rather than direct evidence of racial intent. Furthermore, he contended that even if politics were considered as a motivating factor, it would not negate any potential racial bias involved in creating district lines. In his view, this case represented an instance where race was improperly used as a proxy for political affiliation during redistricting processes - something which should be deemed unconstitutional under existing precedents.