Supreme Court Strikes Down Louisiana Congressional Map in Voting Rights Act Case

By The Editors

*Published: 2026-05-12*

The U.S. Supreme Court, in a 6-3 decision on April 29, ruled that Louisiana's 2024 congressional map violated the Equal Protection Clause of the 14th Amendment by using race as the predominant factor in drawing one district. The case, *Louisiana v. Callais*, centered on Section 2 of the Voting Rights Act (VRA) of 1965.

The ruling came after a series of legal challenges to Louisiana's congressional districting. In 2022, a federal district court and the 5th U.S. Circuit Court of Appeals found that the state's original map likely violated Section 2 of the VRA by diluting Black voting power, as it contained only one majority-Black district out of six, despite Black residents comprising about 33% of the state's voting-age population. This led Louisiana lawmakers to enact Senate Bill 8 (SB8) in 2024, which created a second majority-Black district—District 6—spanning from Shreveport to Lake Charles.

Challengers, including non-Black voters, argued that District 6 constituted an unconstitutional racial gerrymander. A three-judge district court upheld the map, but the Supreme Court reversed that decision. Chief Justice John Roberts, writing for the majority, stated that while Section 2 of the VRA requires states to avoid diluting minority votes, it does not permit race to predominate over traditional districting criteria such as compactness and contiguity. The majority emphasized that Section 2 enforces constitutional protections and does not mandate the creation of majority-minority districts if doing so results in racial gerrymandering.

This decision follows a history of Supreme Court cases interpreting voting rights and equal protection. In *Dred Scott v. Sandford* (1857), the Court ruled that Black people were not U.S. citizens. *Plessy v. Ferguson* (1896) upheld racial segregation under the "separate but equal" doctrine. In *Shelby County v. Holder* (2013), the Court invalidated a key formula used to enforce Section 5 of the VRA's preclearance requirements, shifting the burden to post-enactment challenges under Section 2.

Justice Elena Kagan dissented, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. Quoting Justice Ruth Bader Ginsburg's dissent in *Shelby County*, Kagan wrote that the VRA was "one of the most consequential, efficacious and amply justified exercises of federal legislative power in our Nation’s history." She argued that the majority's ruling marked "this latest chapter in the majority’s now-completed demolition of the Voting Rights Act," contending that Congress, not the Court, should determine the law's ongoing necessity. Kagan noted the VRA's repeated reauthorizations by Congress and its role in advancing democratic participation.

The decision has drawn varied political responses ahead of midterm elections. Democratic leaders have called for legislative action. Representative Ayanna Pressley (D-Mass.) urged Congress to pass the John Lewis Voting Rights Advancement Act and consider Supreme Court reforms, including expansion, term limits, and a binding ethics code. "Every option should be on the table," Pressley said.

State-level elections are also in focus. In Georgia and South Carolina, Democrats aim to elect governors who could counter gerrymandering efforts. The NAACP Legal Defense Fund has highlighted that state officials can enact their own voting rights protections. Nationally, Republicans have redrawn congressional maps in Texas and Florida, while Democrats in California and Virginia have adjusted theirs to achieve greater partisan balance.

In Wisconsin, Democratic gubernatorial candidate Mandela Barnes has pledged that, if elected with a Democratic legislature in 2027, he would redraw the state's congressional maps, which currently favor Republicans 6-2. Barnes stated, "Red states are being given a free pass to rig their maps by disenfranchising Black voters. We can’t sit this fight out."

The ruling does not invalidate Section 2 of the VRA itself. Lower courts will now determine a compliant map for Louisiana, potentially without a second majority-Black district unless drawn without predominant reliance on race. Legal experts note that this upholds longstanding precedents against racial gerrymanders, such as *Miller v. Johnson* (1995) and *Shaw v. Reno* (1993), while preserving Section 2's protections against vote dilution.

Supporters of the map, including Black voters and voting rights groups, argued it remedied the prior VRA violation without excessive racial considerations. Critics of the original 2022 map had successfully invoked Section 2 to challenge Black vote dilution, illustrating the law's dual role in prohibiting both dilution and overreliance on race.

The case underscores ongoing tensions in redistricting litigation. Since *Shelby County*, Section 2 challenges have increased, with courts applying a "totality of circumstances" test from *Thornburg v. Gingles* (1986) to assess dilution claims. In Louisiana, population growth and court orders necessitated the remedial map, but the Supreme Court found the implementation crossed constitutional lines.

Democrats in blue states are also mobilizing against perceived national gerrymandering threats. President Donald Trump's Republican allies have pursued map changes in multiple states, prompting counter-efforts. The Legal Defense Fund encourages state-based voting rights acts as supplements to federal law.

As midterm elections approach, candidates in gubernatorial and legislative races across the South and battlegrounds like Wisconsin emphasize redistricting authority. Louisiana must now develop a new map compliant with both the VRA and the Constitution, likely influencing the 2026 congressional delegation.

This decision continues the Court's role in balancing federal voting rights protections with state sovereignty and equal protection principles, a dynamic rooted in post-Civil War amendments and 20th-century civil rights legislation.

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