Case Summary: NC State Conference of NAACP v. McCrory
By Nate Cook
Elon University School of Law May ’17[1]
Edited by Anthony Rascati, Elon University School of Law Dec. ’17 and Mike Casterlow, Elon University School of Law Dec. ’17
North Carolina State Conference of NAACP v. McCrory, 831 F.3d 204 (4th Cir. 2016).
On July 29, 2016, the 4th Circuit struck down North Carolina’s Voter ID law, finding that the law at issue “target[ed] African Americans with almost surgical precision.”[2] This decision had an immediate impact, as it changed the rules for voting in the 2016 election. While elimination of the photo ID requirement was the most covered and discussed provision struck down by the court, other important provisions were changed by the court’s decision, such as the days allowed for early voting, the use of same-day registration, out-of-precinct provisional voting, and preregistration of 16- and 17-year-olds. To fully understand the gravity of this case, one must look first to the Voting Rights Act of 1965 that was passed to prohibit racial discrimination at the ballot box. Furthermore, it is important to understand the effect of the Supreme Court’s decision in the Shelby County[3] case, and how that case has since changed the political landscape for election legislation across the country. As is frequently now the case, North Carolina’s political climate is a microcosm of American politics, where partisanship plays an ever-increasing role. Republican-controlled legislatures across the country have made many recent attempts to change voting and election procedures in the wake of Shelby County, and North Carolina led the march. The 4th Circuit’s decision in this case illustrates how courts may interpret voting rights cases post-Shelby County, and provides insight that is very valuable for anyone interested in American election law and voting rights.