To Racial Gerrymander or to Not: Electoral Map with Black Majority Districts Back at the Supreme Court

On Monday, March 24th, 2025, the congressional district map of the state of Louisiana was in front of the Supreme Court for the second time in the past decade. Louisiana officials and civil rights groups are fighting for a newly redrawn electoral map that will raise the number of Black majority districts in the state from one to two, as Black people make up nearly one-third of Louisiana's population [1]. Louisiana has six congressional districts, meaning that for Black representation to be heard, civil rights groups argue that two of those congressional districts must hold a majority of Black voters. This case is an appeal following a District Court finding that a map with only one Black majority congressional district violated Section 2 of the Voting Rights Act of 1965 by giving less of a voice to Black voters. 

State officials and advocacy groups that oppose the new map argue that it is a violation of the 14th Amendment's Equal Protection Clause [2]. Equal protection inherently limits the use of race as a factor in redistricting. Racial gerrymandering argues that the voting power of racial minorities cannot be suppressed in the drawing of a map, but here, defendants argue that racial minorities are being inappropriately amplified by the drawing of this new map with two Black majority districts. The new map has a district with what Chief Justice Roberts has described as a snake, with unusual boundaries drawn [3].

This case has been through the Courts for over two years now. In June 2022, Judge Shelly Dick of the United States District Court for the Middle District of Louisiana ruled by invalidating Louisiana’s congressional map with only one Black majority district, arguing that it violated Section 2 of the Voting Rights Act by diluting the impact of Black voters [4]. Judge Dick issued a preliminary injunction on the map from being used in any future elections, with requirements for a new map in accordance with Section 2 of the Voting Rights Act. Immediately following this ruling, the defendants appealed to the United States Court of Appeals for the Fifth Circuit. The Supreme Court ended up hearing the case, and subsequently put it on hold to deal with a similar case occurring in Alabama [5].

The Roberts Court has shown support for electoral maps that promote Black majority districts that align with Census data. In a similar case to Louisiana’s, the liberal wing of the Supreme Court was joined by Conservative Justices Roberts and Kavanaugh to support a map that gave a second Black majority congressional district to Alabama [6]. The ruling acknowledged that while race may have been a factor considered, it was just one of the many used, and Section 2 of the Voting Rights Act of 1965 doesn’t mean that one must be entirely “blind to race”, and to ask such is more or less impossible.

It is important to recognize why congressional district maps and their make-ups are so crucial in elections, especially those of Louisiana. The current Republican Speaker of the House, Mike Johnson, is from Louisiana’s fourth congressional district. Very often in midterm elections, there is a prediction of a wave of Representatives and Senators elected of the opposite party as the one elected to the White House two years prior, leaving many predicting a blue wave of Democrats elected in 2026. Statistics show that Black voters tend to lean more Democratic, especially in Louisiana. Of the almost 1.1 million Democrats in Louisiana, approximately 63% of those registered voters are Black individuals [7]. On the other side of the aisle, only 23,000 of the almost 1.05 million Republican registered voters in Louisiana are Black voters [8]. Having a second Black majority district in Louisiana makes it likely that in 2026, Louisiana would elect another Democrat to the House of Representatives. This threatens the majority in the House that makes up the trifecta that Republicans currently hold. 

The major legal question left for the Supreme Court to finally tackle this session is whether or not Louisiana's new map was drawn with race as the main determining factor. The Roberts Court will likely issue a ruling on this case in June 2025, and while they have supported Black voters like in the Alabama case, it is a much different political climate in June 2025 than in June 2023. With pressures from the Trump administration and Roberts' questions during the oral arguments, it points towards the Court’s willingness to rule against the two Black majority districts. While this ruling is in response to a map in Louisiana, the findings will impact redistricting across the country. 

Sources:

1. Chung, Andrew, Kruzel, John, US Supreme Court Wrestles with Louisiana Electoral Map with More Black-Majority Districts, Reuters (March 24, 2025), https://www.reuters.com/world/us/us-supreme-court-scrutinize-louisiana-electoral-map-with-more-black-majority-2025-03-24/ 
2. Id.
3. Id.
4. Robinson v. Landry 3:22-cv-00211-SDD-RLB
5. Chung, Andrew, US Supreme Court Tosses Race-Based Dispute Over Louisiana Electoral Map, Reuters (June 26, 2023), https://www.reuters.com/legal/us-supreme-court-tosses-race-based-dispute-over-louisiana-electoral-map-2023-06-26/ 
6. Allen v. Milligan 143 S. Ct. 1487
7. Louisiana Secretary of State, Statewide Report of Registered Voters, (2025), https://electionstatistics.sos.la.gov/Data/Registration_Statistics/statewide/2025_0401_sta_comb.pdf 
8. Id.