The Supreme Court ruled 6-3 in Louisiana v. Callais on April 29 that Louisiana's 2024 congressional map, which contained two majority-Black districts drawn under federal court order to comply with Section 2 of the Voting Rights Act, constituted an unconstitutional racial gerrymander under the Fifteenth Amendment. Justice Samuel Alito delivered the opinion of the Court, joined by Chief Justice John Roberts and Justices Clarence Thomas, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett. Justice Thomas filed a concurring opinion, joined by Justice Gorsuch, that would have gone further than the majority. Justice Elena Kagan filed a dissenting opinion, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson. The Court issued a separate order on May 4 granting the respondents' motion for judgment forthwith, which made the decision effective immediately and required Louisiana to draw a new map for the 2026 congressional elections.

The decision narrows the legal framework under which states have drawn congressional and state legislative districts since the early 1990s, when Section 2 of the Voting Rights Act was last interpreted by the Court at length. The practical effect for the 2026 election cycle is that several pending Section 2 challenges to congressional maps in other states will now be evaluated under the standard articulated in Callais, which makes it more difficult to require states to draw majority-minority districts and easier for plaintiffs in racial gerrymandering cases to challenge maps where race was a predominant factor.

What the Court Held

The majority opinion holds that when a state draws a district where race is the predominant factor, the resulting map is subject to strict scrutiny under the Fourteenth and Fifteenth Amendments, and that the asserted state interest of complying with Section 2 of the Voting Rights Act does not by itself satisfy strict scrutiny unless the state demonstrates that the specific map was narrowly tailored to remedy a documented Section 2 violation. The Louisiana map, the Court held, did not meet that standard because the legislature drew the second majority-Black district under court order without conducting an independent analysis of whether Section 2 actually required that specific district configuration.

Alito's opinion is careful to limit the holding. The Court does not strike down Section 2 itself, does not overrule Allen v. Milligan, and does not hold that majority-minority districts are categorically unconstitutional. The opinion holds instead that the Voting Rights Act, when invoked as the basis for race-conscious redistricting, must be applied with greater precision than the lower courts have required and that the federal courts that supervise Section 2 remedial maps must make specific findings rather than accept legislative compliance at face value.

Thomas's concurrence, joined by Gorsuch, would have gone considerably further. Thomas argues that Section 2 of the Voting Rights Act, as currently interpreted by the lower courts, is irreconcilable with the Fifteenth Amendment's prohibition on race-based government action and that the Court should hold the statute unconstitutional as applied to the redistricting context. The concurrence does not command a majority and is not binding precedent, but the position it stakes out signals that two members of the current Court are prepared to take a more aggressive view of the constitutional problem in future cases.

Kagan's dissent argues that the majority has effectively gutted Section 2 of the Voting Rights Act through the back door, by setting a strict-scrutiny standard for race-conscious redistricting that is impossible for states to satisfy while also complying with the statute the Court declines to strike down. The dissent quotes extensively from the legislative history of the 1965 Voting Rights Act and the 1982 amendments and argues that the majority has misread both the statute and the Fifteenth Amendment.

What the Map Looked Like

The Louisiana map at issue was drawn by the state legislature in 2024 under court order from the Middle District of Louisiana, which had found that the previous Louisiana map violated Section 2 of the Voting Rights Act because it contained only one majority-Black district despite the state's Black voting-age population of approximately 33 percent. The legislature drew a new map with two majority-Black districts, the Second District anchored in New Orleans and the Sixth District extending from Shreveport through Baton Rouge to the eastern parishes. The Sixth District in particular drew criticism for its unusual shape, which connected geographically distant Black population centers along a narrow corridor that some commentators compared to the districts struck down in Shaw v. Reno in 1993.

A group of Louisiana voters, led by named plaintiff Phillip Callais, challenged the new map under the Fourteenth and Fifteenth Amendments, arguing that race had been the predominant factor in the legislature's drawing of the Sixth District and that the resulting district was an unconstitutional racial gerrymander. A three-judge district court agreed and enjoined the use of the map. Louisiana appealed and the Supreme Court agreed to hear the case in its 2025-2026 term.

What Happens Next

The May 4 forthwith order gave Louisiana a tight timeline to redraw its congressional map for the 2026 elections. The state legislature will reconvene in special session beginning May 19 to address the remand. Several Republican legislators have indicated that they will propose maps with one majority-Black district rather than two. Civil rights groups have indicated that they will challenge any such map under Section 2 of the Voting Rights Act, setting up another round of litigation that will likely be resolved on the new Callais standard.

Beyond Louisiana, the decision will reshape pending litigation in several other states. Section 2 challenges to congressional maps in Georgia, Alabama, and South Carolina are at various stages of litigation in federal district courts. The lower courts in those cases will now have to apply the Callais standard, which makes it harder for plaintiffs to obtain remedial orders requiring the creation of majority-minority districts. The Republican State Leadership Committee released a statement Wednesday calling the decision "a return to color-blind constitutional principles" and indicating that several Republican-controlled state legislatures are reviewing whether to draw new maps that would not have been permissible under the previous legal framework.

The Conservative Constitutional Argument

The Callais decision reflects a long-running conservative legal argument that the Voting Rights Act, as it has been applied since the 1990s, has produced a regime in which the federal government effectively requires states to engage in race-based districting in order to comply with a statute that was originally enacted to prevent racial discrimination in voting. The argument, articulated in conservative legal scholarship for decades and developed most prominently in the work of legal scholar Edward Blum and former Solicitor General Paul Clement, is that the Constitution's color-blind ideal cannot coexist with a statutory regime that requires racial classification in the drawing of legislative districts.

Critics of the decision, including the Brennan Center for Justice and the NAACP Legal Defense Fund, argue that the practical effect of Callais will be a sharp reduction in minority representation in state legislatures and the U.S. House of Representatives, and that the decision misreads both the original meaning of the Fifteenth Amendment, which they argue was specifically designed to permit race-conscious remedies for documented racial discrimination, and the legislative purpose of the 1965 Voting Rights Act and its 1982 amendments. The Campaign Legal Center has indicated that it will continue to bring Section 2 cases under the new standard but acknowledged in a Wednesday statement that the standard will make those cases substantially more difficult to win.

The Department of Justice's Civil Rights Division, which had filed an amicus brief supporting Louisiana's position that the map was constitutional, declined to comment on the decision. Attorney General Pam Bondi issued a brief statement Tuesday saying that the Department would "continue to enforce the Voting Rights Act consistent with the Court's ruling," language that civil rights organizations interpreted as a signal that federal Section 2 enforcement will be substantially scaled back under the current administration.

The next major test of the Callais standard will come in the Alabama redistricting case currently pending before the Eleventh Circuit, with oral argument scheduled for June. The decision will be cited extensively in that case and in the parallel litigation that is expected to follow in other states across the 2026 election cycle.