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Louisiana v. Callais

United States Supreme Court
146 S. Ct. 1131 (2026)

Written by Jamie Milne, JD

Facts

The 2020 census prompted Louisiana (defendant) to redraw its congressional districts. Like its predecessor, the new congressional map, HB1, had one majority-Black district. In 2022, a federal district court held, in Robinson v. Ardoin, that HB1’s failure to include a second majority-Black district likely violated § 2 of the Voting Rights Act. The decision was based in part on illustrative maps that showed a second majority-Black district was possible. The maps did not, however, satisfy Louisiana’s political goals for districting, including the protection of certain incumbents. Because of Robinson, Louisiana created a new map, SB8, which included a second majority-Black district. Phillip Callais and others (plaintiffs) promptly sued Louisiana, arguing that SB8 constituted racial gerrymandering that violated the Equal Protection Clause. The district court agreed, concluding that the second majority-Black district, which sliced through metropolitan areas to incorporate pockets of predominantly Black populations across four major cities, demonstrated unconstitutional racial gerrymandering. The court rejected Louisiana’s argument that compliance with the Voting Rights Act was a compelling government interest such that SB8 satisfied the strict scrutiny necessary for a racially discriminatory government action to be constitutional. Louisiana appealed.

Rule of Law

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Issue

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Holding and Reasoning (Alito, J.)

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Concurrence (Thomas, J.)

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Dissent (Kagan, J.)

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