Supreme Court Rejects Louisiana Congressional Map in Voting Rights Case

The Supreme Court, in *Louisiana v. Callais*, ruled 6-3 against a Louisiana congressional map on Wednesday. The court found the map, which established a second majority-Black district, constituted unconstitutional racial gerrymandering. The decision affirms a lower court's injunction, preventing the state from using the map in future elections.

A group of voters challenged the 2024 map, alleging it violated the Constitution's equal protection clause by sorting voters based on race. The challenge followed the state's attempt to redraw its congressional districts after the 2020 census. The initial 2022 map contained one majority-Black district out of Louisiana's six congressional seats.

Black voters, comprising approximately one-third of Louisiana's population, filed suit against the 2022 map, claiming it violated Section 2 of the Voting Rights Act, which prohibits voting discrimination. A federal judge agreed the 2022 map likely violated Section 2. The U.S. Court of Appeals for the 5th Circuit upheld this ruling, instructing Louisiana to create a new map by January 2024.

Louisiana adopted a new map in 2024, creating a second majority-Black district. Cleo Fields, a former congressman, was elected in November 2024 to represent the newly drawn district. The 2024 map prompted the lawsuit leading to Wednesday’s Supreme Court opinion.

A three-judge federal district court sided with the plaintiffs, blocking the state from future use of the 2024 map based on claims of racial gerrymandering. However, the Supreme Court temporarily paused this ruling in May 2024.

The Supreme Court heard oral arguments in the case in March 2025 and again in October 2025. The justices instructed litigants to file additional briefs addressing potential violations of the 14th or 15th Amendments in the state's creation of a second majority-minority district.

According to Justice Samuel Alito, who wrote the majority opinion, the Constitution generally prohibits federal or state governments from discriminating based on race. Alito stated the core question before the court was whether compliance with the Voting Rights Act constituted a compelling enough interest to justify racial discrimination. Alito wrote that Section 2 of the VRA aims to provide minority voters an equal opportunity to vote for their preferred candidate, but a state can make choices when drawing maps, such as protecting incumbents. Alito wrote that a Section 2 violation occurs only when circumstances suggest intentional discrimination, such as a state rejecting multiple possible maps containing majority-minority districts without legitimate reason.

Alito referenced the *Gingles* test, derived from the 1986 case *Thornburg v. Gingles*, which courts use to assess whether a map dilutes minority voting power under Section 2. He outlined three preconditions: a minority voter group must be numerous and compact enough to constitute a majority in a reasonably configured district; the minority group must vote as a politically cohesive unit; and the majority group must vote as a bloc. Alito noted plaintiffs should provide an alternative map achieving the state’s goals while also creating a majority-minority district. He also said the challengers must demonstrate racial bloc voting is not explainable by partisan affiliation. Alito cited the development of a two-party system in the South and the court’s 2019 ruling in *Rucho v. Common Cause*, which stated federal courts cannot consider partisan gerrymandering claims.

Alito concluded that Louisiana's goal in adopting the 2024 map was racial, enacted in response to a lower court finding the 2022 map likely violated Section 2. He stated that Louisiana lacked a compelling interest to justify using race in drawing the 2024 map because the Black voters challenging the 2022 map failed to prove their Section 2 case because they did not supply an illustrative map protecting the state's Republican incumbents; nor did they adequately demonstrate racial bloc voting independent of partisan affiliation. He stated that there was no objective likelihood that the challenged map was the result of intentional racial discrimination. He deemed the 2024 map an unconstitutional gerrymander.

Justice Clarence Thomas, joined by Justice Neil Gorsuch, wrote a concurring opinion suggesting the Supreme Court should not have interpreted Section 2 of the Voting Rights Act as giving racial groups an entitlement to proportional representation. Thomas stated that Section 2 should not regulate districting at all.

Justice Elena Kagan read a summary of her 48-page dissent, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. Kagan argued the majority’s changes “eviscerate the law” so it will not remedy classic cases of vote dilution. Kagan stated the majority formulates new proof requirements for those who allege vote dilution, without a basis in Section 2's text or in the Constitution. Kagan argued these requirements leverage modern political life by saying that racial identity and party preference are often linked, which gives politicians free rein to adopt partisan gerrymanders. Kagan emphasized that when Congress amended Section 2 of the VRA in 1982, it did so to override the Supreme Court’s decision holding that Section 2 prohibited only intentional discrimination. Kagan said this decision returns Section 2 to what it was before the 1982 amendment by requiring vote-dilution plaintiffs to show both vote dilution and race-based motive. Kagan concluded her dissent by stating "I dissent."