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LOUISIANA v. CALLAIS
Opinion of the Court
In 2022, Louisiana enacted a new map, “HB1,” that
closely resembled its immediate predecessor:
Figure 2. HB1, enacted in 2022
HB1, like its predecessor, included only one district in
which black voters were a majority of the voting-age population. (In the above maps, it is the bat-shaped District 2
that includes much of New Orleans, blue in Figure 1 and
yellow in Figure 2.) As soon as HB1 was enacted, lawsuits
were filed in the Middle District of Louisiana asserting that
the map violated the Voting Rights Act by “ ‘packing’ large
numbers of Black voters into a single majority-Black congressional district . . . and ‘cracking’ the remaining Black
voters among the other five districts.” Robinson v. Ardoin,
605 F. Supp. 3d 759, 768 (2022). After the suit was filed,
the Robinson court issued a lengthy opinion concluding that
HB1 likely violated the Voting Rights Act by failing to include a second majority-black district. The court thus entered a preliminary injunction requiring Louisiana to