In Dickinson v. Indiana State Election Board (1990) and Whitcomb v. Chavis (1971) courts considered whether Marion County state legislative districts were gerrymandered to dilute the votes of Black residents. It was one of two cases originating in Marion County that have been landmark events in the history of racial discrimination in voting (see Whitcomb v. Chavis, 1971).

Dickinson originated in the U.S. District Court for the Southern District of Indiana on appeal to the 7th Circuit Court of Appeals. The U.S. District Court for the Southern District of Indiana dismissed a lawsuit brought by G. Mae Dickinson, a candidate for Indiana House District 49 in Marion County, who alleged that she was a victim of racial gerrymandering. The case revived the discrimination issues at question in Whitcomb. Ultimately, the Indiana General Assembly redrew Marion County’s boundaries into 15 single-member districts, rendering the lawsuit moot.

The plaintiffs, among whom were candidates for the Indiana House of Representatives, alleged that the 1981 reapportionment of some state district boundaries by the Indiana General Assembly counted as racial gerrymandering and thus violated the Voting Rights Act of 1965. The boundaries in question were Districts 49 and 51 located in Marion County. They were three-member, at-large districts. Based on the 1980 census, after the assembly took a predominantly Black section of District 49 and added it to 51; the former was 78 percent white, and the latter was 61.2 percent Black. These figures, the plaintiffs argued, demonstrated that the defendants arranged the boundaries to guarantee that Black residents’ votes were diluted. The plaintiffs proposed that the U.S. District Court create a new district from precincts in Districts 49 and 51 in order to balance racial populations.

The defendants, who were candidates for the State House in District 49, ruled that this action would violate principles of equity and the doctrine of laches, which refers to prejudicial delay on the part of the plaintiffs. They argued that not only would the remedy require enormous and costly action that would disrupt the 1990 general election already underway, but the plaintiffs had also acted without diligence, waiting nine years after the 1980 census.

Southern District Judge Larry McKinney ultimately sided with the defendants, dismissing the lawsuit and arguing that the plaintiffs had not brought court in a timely fashion. The Court also ruled that the proposed remedy would cause “substantial disruption” of the general election and that the “potential for voter confusion and assorted problems” was too great to provide the requested relief.

The plaintiffs appealed the case to the U.S. Seventh Circuit Court of Appeals, which reversed and remanded the decision. The Court of Appeals ruled that though the plaintiffs’ delay “may not have been inexcusable” and any disruption to the election did “not outweigh the plaintiffs’ right to a hearing on the merits.” The plaintiffs then filed an amended complaint that requested the invalidation of the 1990 general election results in Districts 49 and 51. During the course of hearing the new complaint, the Indiana General Assembly replaced the two districts with several new single-member districts, which addressed the plaintiffs’ allegation.

Revised June 2021

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