Supreme Court Revisits Alabama Congressional Map Dispute

The Supreme Court on Monday instructed a lower court to re-examine Alabama's congressional map, previously blocked for allegedly violating Section 2 of the Voting Rights Act. Section 2 prohibits racial discrimination in voting practices.

The justices vacated the lower court's injunction against the map, which Alabama adopted in 2023, and remanded the case for further consideration. The action follows the Supreme Court's recent decision in *Louisiana v. Callais*, a similar case involving a congressional map.

The legal challenge originated five years ago after Alabama implemented a new congressional map after the 2020 census. Black voters and civil rights groups contested the map in federal court, arguing it violated Section 2. They claimed the map diluted Black voting power by dividing Black voters in southern Alabama across three congressional districts, making them a minority in each.

A district court initially sided with the plaintiffs, finding a likely violation of Section 2, and prohibited the state from using the 2021 map. In 2023, the Supreme Court affirmed that decision in *Allen v. Milligan*, but Alabama then created a new map.

In 2023, a federal court determined this second map also likely violated Section 2 and again forbade its use. A court-appointed special master then created an alternative map, which the district court mandated for future elections. In 2025, after a trial, the court ruled the 2023 map intentionally weakened Black Alabamians' voting strength, violating court orders.

Alabama appealed to the Supreme Court, which delayed its review until after the *Callais* ruling on April 29, which involved Louisiana's congressional map. Alabama requested the Supreme Court to immediately halt the lower court's orders against the 2023 map, citing the proximity of the primary election, scheduled for the day after the Supreme Court issued these orders.

Alabama argued its case mirrored Louisiana's, urging the court to allow elections based on lawful policy goals, not race. The state asserted it sought to protect incumbents and avoid prioritizing race when it drew the 2023 map. The Alabama Legislature passed a law enabling a special primary election for affected congressional districts if a federal court allows the 2023 map's restoration.

Justice Sonia Sotomayor dissented from the court's decision, joined by Justices Elena Kagan and Ketanji Brown Jackson. Sotomayor argued the lower court also found Alabama violated the Fourteenth Amendment through intentional vote dilution. Sotomayor described this constitutional finding of intentional discrimination as independent of the legal issues in *Callais*. She also expressed concern that vacating the injunction would disrupt the upcoming primary election, replacing the current map with Alabama's 2023 plan, even with voting underway. She specified that the District Court may decide on remand whether *Callais* affects the Fourteenth Amendment analysis.