Georgia State Conference of the NAACP, et al.v.Fayette County Board of Commissioners, et al.
The NAACP and Black Fayette County voters challenged the at-large method of electing the Board of Commissioners under § 2 of the Voting Rights Act. The Board conceded minority cohesion and majority bloc voting but disputed whether the Black community was sufficiently large and geographically compact and whether the totality of circumstances supported liability; the parties’ experts disagreed on those questions. The Eleventh Circuit vacated summary judgment for the plaintiffs because the district court had weighed disputed evidence and expert credibility, issues that required fact-finding at trial. It remanded for live testimony, cross-examination, credibility determinations, and findings adequate for appellate review, without deciding the vote-dilution merits or the proposed remedial plan; the court left the intervening election results undisturbed.
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