10
LOUISIANA v. CALLAIS
Opinion of the Court
that its districting legislation [wa]s narrowly tailored to
achieve a compelling interest.” Id., at 920. The Court declined to address “[w]hether or not in some cases compliance with the [Voting Rights Act], standing alone, c[ould]
provide a compelling interest independent of any interest
in remedying past discrimination.” Id., at 921. Instead, the
Court explained that the “challenged district was not reasonably necessary under a constitutional reading and application” of the Voting Rights Act, so the State’s goal of
complying with the Act could not supply a compelling interest. Ibid.
We repeated much the same analysis in Shaw v. Hunt,
517 U. S. 899, 908 (1996) (Shaw II ), applying strict scrutiny
to a redistricting plan that a State crafted to comply with
both §2 and §5 of the Voting Rights Act. “[O]nce again,” we
did not reach the question “expressly left open” in Miller:
whether the Voting Rights Act could itself provide a compelling interest to justify race-predominant districting. 517
U. S., at 911. After “assum[ing], arguendo, for the purpose
of resolving this suit, that compliance with §2 could be a
compelling interest,” we held that the plan failed strict
scrutiny because it was not reasonably required under a
constitutional reading and application of the Voting Rights
Act. Id., at 915.
Likewise, in Alabama Legislative Black Caucus v. Alabama, 575 U. S. 254, 259 (2015), we applied strict scrutiny
to a race-predominant districting plan that the State had
created for two purposes: first, to “come close to a one-person, one-vote ideal,” and second, to “ensure compliance”
with §5 of the Voting Rights Act. We held that, even if the
Voting Rights Act could provide a compelling interest, the
map did not satisfy strict scrutiny because it was not required by the Act. Id., at 277. Once again, we left open
whether compliance with the Act “remain[ed] a compelling
interest.” Id., at 279.