Case Explained: CITY OF HAMMOND, INDIANA v. LAKE COUNTY BOARD OF ELECTIONS, et al

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-02

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants, holding that Indiana’s use of the “Missouri Plan” (a hybrid system of gubernatorial appointment followed by retention elections) to select superior-court judges in Lake County does not violate Section 2 of the Voting Rights Act. The court ruled that under the Supreme Court’s recent decision in *Louisiana v. Callais*, liability under Section 2 is imposed only when the circumstances give rise to a strong inference that intentional racial discrimination occurred; evidence of disparate impact or demographic disparities alone is insufficient to establish a violation. The court applied the *Callais* standard, which requires proof of discriminatory intent, and found no such inference in this case. The record demonstrated that Indiana adopted the Missouri Plan for Lake County in 1973 following a study by the Institute for Court Management that identified “pervasive dissatisfaction” with the functioning of the courts due to the pressures and distractions of partisan judicial elections. The court concluded that the legislature’s decision was motivated by concerns regarding judicial administration and the need to limit political influence, rather than by the racial demographics of the county. Additionally, the court rejected the plaintiffs’ argument that an affidavit from a state official describing Lake County as “highly diverse” proved intentional discrimination, noting that the official’s tenure began decades after the law was enacted and that eliminating partisanship is a legitimate state interest compatible with the Voting Rights Act. As a result of this decision, the judgment in favor of the Lake County Board of Elections and other defendants stands, meaning Indiana may continue to use the merit-based appointment and retention election system for its superior-court judges in Lake County without being compelled by federal law to switch to open contested elections.

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