Case Summary
LWV and coalition partner groups filed an amicus brief in the US Supreme Court supporting a new congressional map that created a second majority-Black district to ensure fair representation for Black voters in Louisiana. A previous lawsuit asserted that Louisiana had diluted Black voters’ voting power by failing to draw a second majority-Black district. After a federal court struck down the map, the legislature drew a map with a second majority-Black district. Several individual plaintiffs filed a lawsuit alleging that this map was a racial gerrymander. A panel sided with the plaintiffs, and the case was appealed to the US Supreme Court. LWV and its co-amici argued the panel’s decision was incorrect and that the legislature’s remedial map should be affirmed.
Section 2 of the Voting Rights Act of 1965 states that, “No voting qualification or prerequisite to voting or standard, practice, or procedure shall be imposed or applied by any State or political subdivision in a manner which results in a denial or abridgment of the right of any citizen of the United States to vote on account of race or color.”
In the redistricting context, Section 2 requires states to draw district maps that do not dilute the votes of voters of color. Plaintiffs who assert that a district map dilutes the voters of color must satisfy four tests.
First, plaintiffs must show it is possible to draw a compact district in which people of color who are citizens and of voting age are a majority. Second, plaintiffs must prove that the voters of color in a district are politically cohesive, i.e., they vote together as a bloc for the candidates of their choice. Third, plaintiffs must prove that there is racially polarized voting in the challenged district in which the white voters in the majority vote as a bloc and consistently defeat the candidates supported by the voters of color in the minority. For example, in Allen v. Milligan, a case challenging Alabama’s congressional districts under Section 2 of the Voting Rights Act, the trial court cited expert testimony that Black voters’ support for their candidates of choice was on average over 90 percent, while white voters’ support for those same candidates was below 20 percent on average.
Finally, plaintiffs must prove that, based upon the totality of circumstances, that “political processes leading to nomination or election in the State or political subdivision” are not equally open to non-white populations, preventing them from equally participating in the political process and electing candidates of their choice. Several factors are used by courts in evaluating this test, including, but not limited to: the history of official voting-related discrimination in the state or political subdivision; the extent of racially polarized voting in the state or political subdivision’s elections; and the extent to which minority group members bear the effects of discrimination in areas such as education, employment, and health, which hinder their ability to participate effectively in the political process.
Robinson and Galmon Challenges to 2022 Map
In March 2022, the Louisiana legislature passed a new congressional map with only one majority-Black district, which combined heavily Black cities like New Orleans and Baton Rouge together. Several lawsuits were then filed, in which plaintiffs argued the map divided Black communities and diluted their voting power. These cases, Robinson and Galmon, were consolidated into a single case.
The map was subsequently struck down, and on January 22, 2024, the Louisiana legislature drew a remedial map with two majority-Black congressional districts, which the United States Supreme Court allowed to be used for the 2024 election. On April 25, 2024, the district court dismissed the case at the state’s request, stating the passage of a remedial map meant there was no longer a justiciable dispute for the court to hear.
Callais – Challenge to the 2024 Remedial Map
On January 31, 2024, several plaintiffs filed a lawsuit against the remedial map in the United States District Court for the Western District of Louisiana, arguing it was racially gerrymandered and requesting a new map be imposed. On April 30, 2024, the district court granted an injunction and enjoined the map, a ruling that was appealed to the Fifth Circuit Court of Appeals. The Louisiana Secretary of State, and the plaintiffs in the case challenging the original map (“Robinson plaintiffs”),who had intervened in the lawsuit, requested an emergency stay from the United States Supreme Court, which granted it on May 15, 2024.
The remedial map was used in the 2024 election, in which the new majority-Black district, stretching from Baton Rouge to Shreveport, was won by Democratic candidate Cleo Fields, a Black state senator.
On November 4, 2024, the United States Supreme Court agreed to hear the appeal of the case challenging the remedial map.
On December 26, 2024, LWV, the Lawyers’ Committee for Civil Rights Under Law, NAACP Legal Defense Fund, Asian Americans Advancing Justice (AAJC), Asian American Legal Defense and Education Fund, and Leadership Conference on Civil and Human Rights filed an amicus brief supporting the appellants from Robinson. The brief argued the panel had erred by applying strict scrutiny to the remedial map and declaring it a racial gerrymander, when instead, considering race while drawing districts to comply with Section 2 of the Voting Rights Act was a long-standing, legal practice necessary to comply with federal law. The amici argued that, if sustained, the panel’s decision would place state legislatures in the position of having lawful enactments to comply with Section 2 and ensuring fair representation being presumed unconstitutional and potentially struck down as racial gerrymandering, in violation of decades of United States Supreme Court precedent.
On March 24, 2025, the Supreme Court heard oral arguments. Despite anticipating a decision this term, the Supreme Court issued a statement announcing it would rehear the case. On June 27, 2025, the last day of the Court's October 2024 term, it restored the case to the calendar for re-argument in the October 2025 term.
In October 2025, LWV and partners filed a second amicus brief supporting the appellants from Robinson. On October 15, 2025, the Supreme Court heard oral arguments again.
On April 29, 2026, the Supreme Court issued its opinion in Louisiana v. Callais. The 6-3 majority destroyed the remainder of Section 2 of the Voting Rights Act spurring a redistricting frenzy across the country to draw new maps eliminating majority-minority districts.
LWV Timeline
Federal court strikes down congressional districts
A federal district court issues a preliminary injunction forbidding use of Louisiana’s congressional maps for the 2022 election, ruling plaintiffs are likely to prevail in their challenge under Section 2 of the Voting Rights Act.
United States Supreme Court stays injunction
In a one-page decision, a 6-3 majority of the United States Supreme Court stays the lower court’s injunction, pending a ruling in Allen v. Milligan, a similar case also seeking a second majority-Black congressional district in Alabama under Section 2 of the Voting Rights Act.
United States Supreme Court issues opinion in Milligan
In a 5-4 ruling, the United States Supreme Court upholds a lower court decision requiring Alabama to create a second majority-Black congressional district in compliance with Section 2 of the Voting Rights Act.
Fifth Circuit panel issues order vacating injunction
A panel of the United States Court of Appeals for the Fifth Circuit issues an order affirming the district court’s reasoning for the injunction. The panel’s order vacates the preliminary injunction and orders the district court to give the legislature an opportunity to adopt remedial maps and to hold a trial if no remedial plan was adopted.
Fifth Circuit denies rehearing en banc
The full Fifth Circuit Court of Appeals denies rehearing en banc, after no eligible judges requested a vote on rehearing.
Louisiana enacts new congressional maps
Louisiana Governor Jeff Landry signs new congressional maps into law. The new map includes a second majority-Black district centered on Baton Rouge and Shreveport.
Callais plaintiffs file lawsuit
A group of individual plaintiffs identifying themselves as “non-African American” file a federal lawsuit asserting the remedial map is a racial gerrymander that impermissibly discriminated against voters.
Panel partially grants intervention
The three-judge panel in Callais partially grants intervention to the plaintiffs from Robinson, allowing them to participate at a remedial stage should one become necessary, and allows the state of Louisiana to intervene.
District court dismisses Robinson case
The district court in Robinson dismisses the case, citing the end of a justiciable controversy due to the legislature’s enactment of a new map.
Panel strikes down map
In a 2-1 ruling, the panel issues a preliminary injunction against the remedial map, ruling it is a racial gerrymander in violation of the Equal Protection Clause of the United States Constitution.
Robinson plaintiffs appeal
The intervenors from the Robinson case file a notice of appeal.
United States Supreme Court grants emergency stay
In a 6-3 vote, after emergency applications from both the state of Louisiana and the intervenors from Robinson, the United States Supreme Court stays the panel’s ruling.
United States Supreme Court assumes jurisdiction
The United States Supreme Court notes it has jurisdiction over the appeal and sets oral argument.
LWV files amicus brief
LWV and partner civil rights organizations file an amicus brief supporting the remedial map and pointing out several errors in the panel’s decision striking it down.
Supreme Court announces it will rehear the case next term
On the last day of the October 2024 Supreme Court term, the court announces it will not issue a decision in Louisiana v. Callais, but, instead, will rehear the case next term.
United States Supreme Court orders supplemental briefing
The Court orders the parties to submit supplemental briefing on whether Louisiana's creation of a second majority-Black district violates the Fourteenth or Fifteenth Amendments of the United States Constitution.
LWV files second amicus brief
LWV, with its partners, files a second amicus brief at the United States Supreme Court. The brief argues that drawing majority-minority districts under Section 2 of the Voting Rights Act is constitutional, because states have a compelling interest in ensuring voters of color have an equal opportunity to elect candidates of their choice. Thus, to ensure Section 2 is an effective remedy, consideration of race is necessary.
Supreme Court holds oral argument
The United States Supreme Court hears oral argument on the question presented in the supplemental briefing.
United States Supreme Court issues opinion
The Court strikes down Louisiana’s remedial map as an unconstitutional racial gerrymander under the Fourteenth Amendment to the United States Constitution. The Court then effectively eliminates Section 2 of the Voting Rights Act by rewriting the rules of a Section 2 claim to ensure plaintiffs cannot succeed in future cases challenging racial discrimination in redistricting.