Wayne Ince
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After the 2020 census, Louisiana redrew its 6 congressional districts. The math was stark: Black voters make up 33% of Louisiana's population but held only 1 of 6 seats under the 2022 map — a near-total exclusion from political representation.
A federal court ruled the 2022 map likely violated Section 2 of the Voting Rights Act (VRA) and ordered Louisiana to produce a remedial map. Louisiana responded with SB8 — a second majority-Black district stretching 250 miles from Shreveport to Baton Rouge, connecting Black communities the length of the state.
White voters immediately sued, calling SB8 an "unconstitutional racial gerrymander." That lawsuit became the vehicle the Supreme Court used to dismantle decades of VRA enforcement.
Share of Louisiana residents who are Black
Black representation under the 2022 map
Span of SB8's second majority-Black district
Wayne Ince
2
This is the impossible bind Louisiana — and Black voters — were placed in. Every door was a trap door.
Draw a single majority-Black district after the 2020 census.
Result: Federal court rules this is a VRA VIOLATION. Louisiana is ordered to redraw the map.
Draw SB8 to comply with the federal court's remedial order and Section 2 requirements.
Result: SCOTUS rules this is an UNCONSTITUTIONAL RACIAL GERRYMANDER.
Wayne Ince
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Justice Alito wrote the majority opinion. The Court held that SB8 was an unconstitutional racial gerrymander, that Section 2 of the VRA did not require the second majority-Black district, and that therefore no compelling governmental interest justified the use of race in drawing the district.
"Today's decision renders Section 2 all but a dead letter."
— Justice Kagan, Dissent
Plaintiffs must now prove the state intentionally discriminated. Discriminatory effects alone are no longer sufficient.
Plaintiffs must "disentangle" race from partisan affiliation in racially polarized voting data — an almost impossible evidentiary standard.
Illustrative maps submitted as evidence must satisfy all of the state's stated partisan objectives.
Wayne Ince
4
Callais handed states a legal permission slip for racial voter suppression — and it fits in your back pocket.
If a state can claim partisan motives for its map, that map is effectively shielded from Section 2 VRA challenges — no matter the racial impact.
In the South, race and party are deeply correlated. Black voters vote overwhelmingly Democratic. States can now claim: "We targeted Democrats — not Black people." Courts cannot easily disprove it.
Within weeks of the ruling: Alabama, Florida, Mississippi, Tennessee, and Louisiana all initiated redistricting efforts using the Callais partisan framing to eliminate majority-minority districts.
"The decision permits states to use partisan gerrymandering as a wholesale excuse to deny Black voters a voice in their government."
— NAACP Legal Defense Fund
Wayne Ince
5
This ruling did not happen in isolation. It is the third blow in a deliberate, decade-long campaign to dismantle the Voting Rights Act brick by brick.
Killed VRA Section 5 preclearance. States with documented histories of discrimination no longer need federal approval before changing voting rules.
Federal courts declared powerless to stop partisan gerrymandering. The door opened for unchecked map manipulation.
VRA Section 2 enforcement gutted. Partisan cover legalized as a shield. The last meaningful federal protection for Black voting power is stripped away.
State courts. State constitutions. State legislatures — most of which are themselves products of the very gerrymandering this Court just protected. The federal backstop is gone.
People fought, bled, and died to build the Voting Rights Act. The Court has spent a decade tearing it down one ruling at a time. Callais is not an ending. It is an escalation.
Louisiana v. Callais, 608 U.S. ___ (2026)
Justice Kagan Dissent
Brennan Center for Justice
NAACP Legal Defense Fund
CRS Report LSB11431
State Court Report, May 7, 2026
Wayne Ince
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