Cite as: 608 U. S. ____ (2026) 9 Opinion of the Court was narrowly tailored to vindicate that interest. See, e.g., Students for Fair Admissions, Inc. v. President and Fellows of Harvard College, 600 U. S. 181, 206 (2023) (SFFA). The Court modified this framework for racial gerrymandering cases. Although any use of race in government decisionmaking generally triggers strict scrutiny, in gerrymandering cases a challenger must show that race was the government’s predominant consideration. See Bush v. Vera, 517 U. S. 952, 964 (1996) (plurality opinion). And in cases where race predominated, States would sometimes assert that compliance with the Voting Rights Act provided a compelling interest justifying the use of race. Yet we never decided whether compliance with the Act could constitute a compelling interest. Instead, we repeatedly assumed without deciding that the Voting Rights Act could constitute a compelling interest because in all those cases, the Act actually did not demand the State’s race-predominant districting. Thus, the States in those cases could not satisfy strict scrutiny regardless of whether compliance with the Voting Rights Act could provide a compelling interest. The first case in which the Court explicitly made this assumption was Miller v. Johnson, 515 U. S. 900, 917–920 (1995),1 which concerned a majority-black district that was designed to satisfy the Justice Department’s preclearance demands under §5 of the Voting Rights Act. The Miller Court first found that the legislature had “subordinated traditional race-neutral districting principles, including but not limited to compactness, contiguity, and respect for political subdivisions or communities defined by actual shared interests, to racial considerations.” Id., at 916. For this reason, the Court held, race had predominated in the creation of the new district, and the State had to “demonstrate —————— 1 Such an assumption may have been implicit in Shaw v. Reno, 509 U. S. 630, 653–656 (1993) (Shaw I ).

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