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Louisiana v. Callais

Judgment

Question Presented: Whether compliance with the Voting Rights Act of 1965 provides a compelling reason that may justify the intentional use of race in drawing legislative districts.

Alleged Acts: After the 2020 U.S. Census, Louisiana undertook congressional redistricting. Following the Supreme Court's decision in Allen v. Milligan, a federal court found that Louisiana's existing congressional map violated Section 2 of the Voting Rights Act (VRA) by denying Black voters—who make up roughly one-third of the state's population—an equal opportunity to elect candidates of their choice. Under court order, the Louisiana legislature enacted a remedial map (known as SB8) that created a second majority-minority (majority-Black) district out of the state's six total districts, using 2020 census demographics. This new map was then challenged as a racial gerrymander and a violation of the Fourteenth and Fifteenth Amendments.

Procedural history: Federal district court upheld the new map institutionalizing the majority-minority district as constitutional, which Louisiana subsequently appealed to the Supreme Court.

Summary: Louisiana v. Callais is a landmark redistricting decision in which the Supreme Court ruled that Louisiana's court-ordered remedial congressional map—which created a second majority-Black district—was an unconstitutional racial gerrymander. The Court held that because Section 2 of the Voting Rights Act did not require the creation of that additional majority-minority district, the state lacked a compelling interest to use race-based districting. The decision has been widely viewed as weakening the protections of the Voting Rights Act against racial vote dilution and establishing a new framework for evaluating racial gerrymandering claims.

Conclusion: In a 6–3 decision, the Supreme Court reversed the lower court and held that Louisiana's SB8 map was an unconstitutional racial gerrymander. Writing for the majority, Justice Samuel Alito explained that the Voting Rights Act did not require Louisiana to create an additional majority-minority district. Because no such requirement existed under the VRA, there was no compelling government interest to justify the State's use of race in drawing SB8. Therefore, the map violated the Equal Protection Clause.

Legal Issue(s)

Applicable Law(s): Section 2 of the Voting Rights Act of 1965, Fourteenth Amendment, and Fifteenth Amendment of the United States Constitution

Language of Decision

Geolocation

Latitude: 38.8878

Longitude: -77.0026