4
LOUISIANA v. CALLAIS
Syllabus
(1) The first Gingles precondition is that a community of minority
voters must be sufficiently numerous and compact to constitute a majority in a reasonably configured district. While many §2 plaintiffs
have simply provided illustrative maps with their desired number of
majority-minority districts, such maps prove only that the State could
create an additional majority-minority district, not that the State’s
failure to do so violated §2 of the Voting Rights Act. To show the latter,
plaintiffs’ illustrative maps must satisfy two conditions: Plaintiffs cannot use race as a districting criterion in drawing illustrative maps, and
illustrative maps must meet all the State’s legitimate districting objectives, including traditional districting criteria and the State’s specified political goals. Pp. 29–30.
(2) To satisfy the second and third preconditions—politically cohesive voting by the minority and racial-bloc voting by the majority—the
plaintiffs must provide an analysis that controls for party affiliation,
showing that voters engage in racial-bloc voting that cannot be explained by partisan affiliation. P. 30.
(3) On the “totality of circumstances” inquiry, the focus must be
on evidence that has more than a remote bearing on what the Fifteenth
Amendment prohibits: present-day intentional racial discrimination
regarding voting. Discrimination that occurred some time ago and present-day disparities characterized as ongoing “effects of societal discrimination” are entitled to much less weight. Shaw v. Hunt, 517 U. S.
899, 909–910. Pp. 30–31.
(c) Nothing in Allen v. Milligan, 599 U. S. 1, dictates a different result. That case merely addressed whether Alabama’s novel evidentiary standard required a change to existing §2 precedent. Allen did
not address whether “race-based redistricting” under §2 could “extend
indefinitely into the future” despite significant changes in conditions,
599 U. S., at 45 (KAVANAUGH, J., concurring in part), nor did it address
whether §2 plaintiffs must disentangle race from politics in proving
their case. Indeed, Allen did not address the Fourteenth Amendment
at all. But here, the decision before the Court is based on the Fourteenth Amendment. Pp. 31–32.
(d) Under the updated Gingles framework, the facts of this suit easily require affirmance. Louisiana’s enactment of SB8 triggered strict
scrutiny because the State’s underlying goal was racial. The State configured District 6 to achieve a black voting-age population over 50%
because the Robinson court held that §2 likely required the creation of
an additional majority-black district. The State’s intentional compliance with the court’s demands constituted an “express acknowledgment that race played a role in the drawing of district lines.” Alexander, 602 U. S., at 8.
No compelling interest justifies SB8 because §2 did not require the