The Supreme Court provided additional guidance on the "totality of the circumstances" test in Johnson v. De Grandy (1994). The court emphasized that the existence of the three Gingles preconditions may be insufficient to prove liability for vote dilution through submergence if other factors weigh against such a determination, especially in lawsuits challenging redistricting plans. In particular, the court held that even where the three Gingles preconditions are satisfied, a jurisdiction is unlikely to be liable for vote dilution if its redistricting plan contains a number of majority-minority districts that is proportional to the minority group's population size. The decision thus clarified that Section 2 does not require jurisdictions to maximize the number of majority-minority districts. The opinion also distinguished the proportionality of majority-minority districts, which allows minorities to have a proportional opportunity to elect their candidates of choice, from the proportionality of election results, which Section 2 explicitly does not guarantee to minorities.
The Supreme Court provided additional guidance on the "totality of the circumstances" test in Johnson v. De Grandy (1994). The court emphasized that the existence of the three Gingles preconditions may be insufficient to prove liability for vote dilution through submergence if other factors weigh against such a d.etermination, especially in lawsuits challenging redistricting plans. In particular, the court held that even where the three Gingles preconditions are satisfied, a jurisdiction is unlikely to be liable for vote dilution if its redistricting plan contains a number of majority-minority districts that is proportional to the minority group's population size. The decision thus clarified that Section 2 does not require jurisdictions to maximize the number of majority-minority districts. The opinion also distinguished the proportionality of majority-minority districts, which allows minorities to have a proportional opportunity to elect their candidates of choice, from the proportionality of election results, which Section 2 explicitly does not guarantee to minorities.