Louisiana v. Callais
Case Overview
Following the Supreme Court's 2023 ruling in Allen v. Milligan, Louisiana drew a remedial congressional map creating a second majority-Black district. White and non-Black voters challenged the new map as an unconstitutional racial gerrymander. The Court addressed whether a map drawn in direct compliance with a Voting Rights Act court order survives strict scrutiny under the Equal Protection Clause.
Decision
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Opinion of the Court
The Facts
Louisiana redrew its congressional district map (SB8) ahead of the 2022 elections. The new map created one majority-minority district where the previous map had two. The state argued that the VRA did not require two districts, so using race to pack minorities into one district was permissible.
The Issue
Whether Louisiana's redrawing of its congressional map to create only one majority-minority district, rather than two, violates the Equal Protection Clause because race was a predominant factor in the redistricting decision.
Louisiana argued the VRA permitted this change because it did not mandate two districts. Plaintiffs argued that using race as a predominant factor requires a compelling interest, and the VRA did not create one here.
The Rules
The Constitution almost never permits a state to discriminate on the basis of race. Such discrimination triggers strict scrutiny. The state must show compelling interest and narrowly tailored means.
Compliance with the VRA can be a compelling interest, but only if the VRA actually requires or strongly suggests the race-conscious redistricting the state claims to pursue.
The Application
Voting rights and redistricting are complex. When the VRA was in effect, it pushed states to maintain or create majority-minority districts. But that was a Congressional mandate, not a license to pack minorities into fewer districts. Louisiana's move from two to one majority-minority district—achieved by using race as a predominant factor—looks like dilution, not compliance. The state had to justify the move.
Strict scrutiny asks: did the state have a compelling interest and narrow tailoring? The VRA did not require Louisiana to go from two districts to one. The state's other justifications—traditional redistricting principles, partisan considerations—do not survive strict scrutiny when race was the predominant factor. The tailoring was not narrow; the race-consciousness went too far.
The Conclusion
**The Supreme Court held that Louisiana's SB8 is an unconstitutional racial gerrymander.** The state used race as a predominant factor without a compelling interest. The VRA did not require the change from two districts to one. The judgment was rendered for the plaintiffs.
The decision reaffirms that race-based redistricting requires real justification, not hypothetical VRA concerns.
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