
Center for Policy Analysis and Research
Voting Rights and Civic Engagement
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Center for Policy Analysis and Research
Voting Rights and Civic Engagement

In Louisiana v. Callais, the Supreme Court limited the circumstances under which race can be considered in drawing congressional districts under the 1965 Voting Rights Act (VRA). The decision is expected to have far-reaching implications for future redistricting cases, voting rights litigation, and minority representation in elections nationwide.
Racial gerrymandering: The practice of rigging electoral maps to benefit or disadvantage a particular racial group
Majority-minority district: Electoral districts primarily comprised of a racial or ethnic minority population.
Section 2 of the Voting Rights Act: Authorized the creation of majority-minority districts to remedy decades of racial gerrymandering that disenfranchised Black Americans.
Preclearance: A provision in the Voting Rights Act that required jurisdictions with a history of voter discrimination to clear changes in election laws with the United States Attorney General or a federal court prior to their enactment
Shelby County v. Holder: A 2013 Supreme Court ruling that declared preclearance unconstitutional.

• Following the 2020 Census, the Louisiana legislature adopted a congressional map in which one of the state’s six congressional districts had a majority-Black population. Based on the 2020 Census data, civil rights advocates argued that the state should have two majority-minority districts to ensure equal representation of Black voters. Despite these criticisms and Democratic Governor John Bel Edwards’s veto, the state legislature passed the map in February 2022.
• In March, a coalition of impacted voters, local advocacy groups, and national civil rights organizations, including the Legal Defense Fund and the American Civil Liberties Union, filed a lawsuit against Louisiana’s Secretary of State arguing that the electoral map violated Section 2 of the VRA for “dilut[ing] the voting power of Black Louisianans by failing to provide Black voters an equal opportunity to elect their candidates of choice in a second Louisiana congressional district.”1
• The plaintiffs won and, in January 2024, Louisiana implemented a new congressional map with two majority-minority districts. The map was used in the 2024 election, and Louisiana elected Representative Cleo Fields to the U.S. House of Representatives, joining Congressional Black Caucus Member Representative Troy A. Carter as the first two Black elected officials to represent Louisiana in the U.S. Congress at the same time.
In 2025, a group sued the state of Louisiana, arguing that the state’s congressional map relied on racial gerrymandering and violated the Equal Protection Clause of the 14th Amendment. The defendants, including Black Louisianans represented by the LDF, argued that the map complied with Section 2 of the VRA. A federal court agreed with the complainants and issued an injunction preventing the map from being used in future elections. The defendants appealed, and the U.S. Supreme Court decided to hear the case.

On April 29, 2026, in a 6-3 decision, the Supreme Court upheld the federal court’s ruling and determined that Louisiana’s congressional map was an unconstitutional racial gerrymander. In the majority opinion, the justices asserted that Section 2 of the VRA does not require proportional representation of minority groups in electoral maps and should only be applied to remedy intentional racial discrimination, which they did not find evidence of in Louisiana.2 In the dissenting opinion, which Justice Sonia Sotomayor read aloud from the bench, the justices state that this ruling was a “demolition of the Voting Rights Act” that will “set back the foundational right Congress granted of racial equality in electoral opportunity.”3
Within a week of the decision, Louisiana Governor Jeff Landry (R) suspended the state’s U.S. House primary elections as state officials moved to revise the congressional map just months before the 2026 midterm elections.4 The state plans to discard the ballots of more than 45,000 voters who have already submitted absentee ballots or voted by mail prior to the suspension.5 On May 29, the Louisiana state legislature passed a map that eliminated one of the majority-Black districts. Hours later, Governor Landry signed it into law.
Since the Supreme Court’s 2013 decision in Shelby v. Holder, Southern states previously subject to preclearance have passed electoral maps and voting laws that restrict the right to vote. In response to the Supreme Court’s decision in Callais, several states have taken steps to redraw their electoral maps in ways that may dilute minority electoral power.
• Alabama: Governor Kay Ivey (R) called a special session of the legislature to potentially amend its congressional map. The legislature passed a new map that eliminated one of the majorityBlack districts. However, on May 26, a federal court struck down the map, ruling that it was “tainted by intentional race-based discrimination.”6 Alabama Attorney General Steve Marshall appealed the decision to the U.S. Supreme Court, which approved the use of the new map in the 2026 midterm election. 7
• Florida: On May 4, Governor Ron Desantis (R) signed a new congressional map into law that divided Latinx communities, changing the makeup of one district from 51% Hispanic to 36% Hispanic.8 On May 26, a circuit court judge upheld the map for use in the 2026 midterm elections. Voting rights organizations, including the Campaign Legal Center and Southern Poverty Law Center, intend to appeal the decision.9
• Georgia: Governor Brian Kemp (R) called a special session of the state legislature in June to consider redrawing its electoral map for 2028.10 After facing public pressure, the legislature declined to conduct redistricting during the special session but is likely to revisit the issue before the 2028 Presidential election.11
• Mississippi: The Supreme Court reopened the door for Mississippi to redraw its electoral map by reversing the state court’s ruling that the state electoral map unlawfully dilutes Black voting strength.12
• South Carolina: South Carolina Governor Henry McMaster (R) called a special session on May 15 to conduct congressional redistricting. The State House of Representatives passed a map that would have eliminated the only congressional district held by a Democrat, but the State Senate declined to vote on the map until the next legislative session, citing that early voting had already begun.13
• Tennessee: The Tennessee legislature approved a congressional map that divided Memphis, a predominantly Black city that had previously comprised a single congressional district, among four separate districts.14
This decision is expected to have significant long-term implications for electoral representation and voting rights. By narrowing the scope of Section 2 of the VRA, the ruling will make it more difficult to challenge electoral maps that reduce the voting influence of racial and ethnic minority communities. As states reconsider and redraw district maps in the wake of Callais, the ruling will shape future patterns of political representation at both the state and national levels. In 2023, all but two majority-Black districts were represented by members of the Congressional Black Caucus (CBC). In 2025, the CBC swore in 62 Members, its largest membership class in history. In response to the Callais decision, CBC Chair Representative Yvette D. Clarke warned that up to 19 Members are at risk of losing their seats due to redistricting efforts. 15

Alabama Representative Shomari Figures and Representative Terri A. Sewell both represent majorityminority districts susceptible to major demographic changes after the Callais decision. In June, the Supreme Court approved use of a map that had been deemed discriminatory by a lower court, leaving the CBC Members’s seats in limbo.
The new map signed into law by Governor Landry eliminates Representative Cleo Fields’ seat and makes Representative Troy A. Carter’s path to reelection more difficult in the district he has represented since 2021
In May, the Missouri Supreme Court upheld a map that removes nearly 70,000 minority voters from the district Representative Emanuel Cleaver II has represented since 2005.16 The demographic shifts put Rep. Cleaver at risk of losing his seat in November.
In 2024, Representative Don Davis won his first congressional race by 6,000 votes. One year later, the North Carolina state legislature passed a new electoral map that leaves Rep. Davis vulnerable to losing his seat in November.17
The South Carolina Senate’s decision to maintain the existing congressional map for its primaries preserved Representative James Clyburn’s seat in the district that he has represented since 1992. The state legislature may take up the issue again when the next legislative session begins on June 10, but the delay will likely prevent a new map from going into effect for the 2026 midterm elections.
Texas was one of the first states to begin mid-decade redistricting efforts, implementing a new map in August 2025. In April 2026, the Supreme Court affirmed this map for use in the 2026 midterm elections. As a result, Representative Al Green could no longer run in the district he has represented since 2005. In the 2026 primary election, he ran in a different district and was defeated by fellow CBC Member and incumbent Representative Christian D. Menefee. In addition, the district Representative Marc Veasey has represented since 2013 underwent major demographic shifts. Rep. Veasey declined to run for Congress again, choosing instead to end his term at the end of 2026.18 The new map also rendered Representative Jasmine Crockett ineligible to run in the district she has represented since 2023. Rep. Crockett opted to run for U.S. Senate instead, where she lost the Democratic primary.
The decision is likely to shape the legal and political landscape leading into the 2026 midterm elections and the 2028 presidential election.
• States may redraw electoral maps, including changes to majority-minority districts.
• Courts are expected to continue reviewing legal challenges related to redistricting efforts following the Callais decision.
• Members of the Congressional Black Caucus have renewed calls for passage of the John Lewis Voting Rights Advancement Act, which would restore and strengthen key protections under the VRA.
1. ROBINSON V. LANDRY: Challenging Louisiana's Congressional Map
2. Louisiana v. Callais | Oyez
3. 24-109 Louisiana v. Callais (04/29/2026)
4. Louisiana congressional primaries suspended after Supreme Court ruling | AP News
5. Louisiana’s governor on the Supreme Court decision and his suspending of House primary elections - CBS News
6. Federal court blocks Alabama from eliminating majority-Black district
7. Supreme Court Clears the Way for Republican-Friendly Map in Alabama - The New York Times
8. Florida redistricting ramifications will affect five key districts
9. Judge upholds Florida congressional map changes
10. Georgia Gov. Brian Kemp calls special legislative session to redraw congressional map after Supreme Court ruling - CBS Atlanta
11. Georgia Republicans Shelve Redistricting As Anger Grows - The New York Times
12. Supreme Court reverses Mississippi redistricting ruling - Mississippi Today
13. South Carolina Senate kills redistricting before midterms, bucking Trump
14. Tennessee approves new congressional map that dissolves majority Black district - CBS News
15. Democrats warn a third of the Congressional Black Caucus could be wiped out by redistricting wars
16. Missouri Supreme Court ruling could reshape 2026 congressional races
17. NC Democrat Don Davis launches campaign in newly gerrymandered congressional district
18. North Texas Congressman Marc Veasey discusses his decision against running for reelection and for Tarrant County Judge - CBS Texas
July 2026
Center for Policy Analysis and Research
Voting Rights and Civic Engagement
