Cite as: 608 U. S. ___ (2026)
3
Syllabus
Congress the “power to enforce [the Amendment] by appropriate legislation.” As the Court has long held, the Fifteenth Amendment bars
only state action “ ‘motivated by discriminatory purpose.’ ” Reno v.
Bossier Parrish School Bd., 520 U. S. 471, 481. So a law that seeks to
enforce the Fifteenth Amendment by prohibiting mere disparate impact would fail to enforce a right that the Amendment secures. That
is never “appropriate,” South Carolina v. Katzenbach, 383 U. S. 301,
308, because Congress cannot “enforce a constitutional right by changing what the right is,” City of Boerne v. Flores, 521 U. S. 507, 519. For
this reason, the focus of §2 must be enforcement of the Fifteenth
Amendment’s prohibition on intentional racial discrimination. When
§2 of the Act is properly interpreted, it imposes liability only when circumstances give rise to a strong inference that intentional discrimination occurred. Properly understood, §2 thus does not intrude on States’
prerogative to draw districts based on nonracial factors, including to
achieve partisan advantage. In short, §2 imposes liability only when
the evidence supports a strong inference that the State intentionally
drew its districts to afford minority voters less opportunity because of
their race. Not only does this interpretation follow from the plain text
of §2, but it is consistent with the limited authority that the Fifteenth
Amendment confers. Pp. 22–26.
(b) This interpretation does not require abandonment of the framework for evaluating §2 claims that the Court established in Thornburg
v. Gingles, 478 U. S. 30. The Court need only update the framework
so it aligns with the statutory text and reflects important developments since the Court decided Gingles 40 years ago. Four historical
developments are of particular note. First, vast social change has occurred throughout the country and particularly in the South, which
have made great strides in ending entrenched racial discrimination.
Second, a full-blown two-party system has emerged in the States
where §2 suits are most common, and there is frequently a correlation
between race and party preference. Third, in Rucho v. Common Cause,
588 U. S. 684, this Court held that partisan gerrymandering claims
are not justiciable in federal court, and this holding creates an incentive for litigants to exploit §2 for partisan purposes by “repackag[ing]
a partisan-gerrymandering claim as a racial-gerrymandering claim,”
Alexander v. South Carolina State Conference of the NAACP, 602 U. S.
1, 21. Fourth, the increased use and capabilities of computers in drawing districts and creating illustrative maps means that a §2 plaintiff
can easily identify an alternative map that fully achieves all the State’s
legitimate goals while producing greater racial balance, if such a map
is possible. In light of these developments, the Court updates the Gingles framework and realigns it with the text of §2 and constitutional
principles. Pp. 26–31.