In a major ruling on Wednesday, the Supreme Court struck down a Louisiana congressional map featuring two majority-Black districts, while simultaneously rewriting the rules for how minority voting power is protected across the United States.
In a 6-3 decision in Louisiana v. Callais, the Court’s conservative majority held that Louisiana’s “SB8” map was an unconstitutional racial gerrymander.
The ruling goes far beyond the Bayou State, however, as the Court established a more rigorous standard for plaintiffs attempting to prove that a state has diluted the voting strength of racial groups.
Writing for the majority, Justice Samuel Alito announced that the Court was “updating” the framework used for 40 years to evaluate the Voting Rights Act (VRA). Under the new “Callais requirements,” the Court shifted the focus from the effects of a map to the intent of the lawmakers who drew it.
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The Court held that Section 2 of the VRA must be interpreted to align with the Fifteenth Amendment’s ban on intentional discrimination. “Properly understood, §2 does not intrude on States’ prerogative to draw districts based on nonracial factors, including to achieve partisan advantage,” Alito wrote.
Key changes to the legal standard include:
- Political Goals as a Shield: Plaintiffs must now provide illustrative maps that satisfy all of a state’s “legitimate districting objectives,” including partisan goals and protecting specific incumbents.
- Disentangling Race and Politics: To prove “racial-bloc voting,” plaintiffs must provide statistical evidence that controls for party affiliation, showing that voting patterns are caused by race rather than partisan preference.
- Emphasis on Current Data: The Court ruled that historical evidence of discrimination is entitled to “much less weight” than evidence of present-day intentional discrimination.
The case centered on Louisiana’s 2024 map, which created a second majority-Black district (District 6) that stretched 250 miles from Shreveport to Baton Rouge. Louisiana leaders had drawn the map after a lower court warned that their previous map likely violated the VRA.
However, the Supreme Court ruled that because the VRA did not actually require that second district under the newly clarified standard, the state had no “compelling interest” to use race as the primary factor in drawing the lines.
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“Louisiana’s enactment of SB8 triggered strict scrutiny because the State’s underlying goal was racial,” Justice Alito wrote, noting that the state’s map was an attempt to satisfy court demands while protecting Republican incumbents like House Speaker Mike Johnson.
The ruling drew a sharp rebuke from the Court’s three liberal members. In a passionate dissent, Justice Elena Kagan accused the majority of “eviscerating” the Voting Rights Act and ignoring the “results test” mandated by Congress in 1982.
“Under the Court’s new view… a State can, without legal consequence, systematically dilute minority citizens’ voting power,” Kagan wrote. She argued that the new requirements would allow states to “crack” minority communities by simply claiming they were seeking a partisan advantage.
Kagan characterized the decision as the final step in a decade-long effort to dismantle the VRA, following previous rulings that limited federal oversight and weakened protections against discriminatory voting rules.
Justice Clarence Thomas, joined by Justice Neil Gorsuch, wrote a concurring opinion arguing that the Court should go even further and hold that Section 2 of the VRA does not apply to redistricting at all.
The case has been remanded to the lower court for further proceedings, but the ruling effectively halts the use of Louisiana’s SB8 map for upcoming elections.
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