November 28, 2025
This year, the Supreme Court is poised to make a landmark ruling regarding the legality of racial gerrymandering in America. In a rare occurrence, the Supreme Court is choosing to rehear a case that was argued only a year prior on the topic of majority minority districts. In that instance, the Supreme Court issued a brief order of action to the plaintiffs but did not rule on the underlying merits of the case [1].
The controversy surrounds the status of Louisiana’s sixth voting district. After the 2020 census, Louisiana redrew its congressional maps. In its new map, Louisiana had six districts, but only one was a majority black district. Opponents took this congressional map to the courts a year ago in Robinson v. Ardoin, wherein critics argued that Louisiana’s map diluted the black vote by only having one majority black district, despite one-third of the state’s population being African-American [2]. The court determined that Louisiana’s map was in violation of section 2 of the Voting Rights Act of 1965, which 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 to deny or abridge the right of any citizen of the United States to vote on account of race or color” [3]. Thus, the court determined that by only having one majority black population, Louisiana was unlawfully underrepresenting its black population.
Opponents of the new map, as represented by Callis, argue that the inclusion of a second majority black district is a form of racial gerrymandering as it abridges the voting power of white Americans. In a brief to the Supreme Court, these critics contend that the new map “uses race as a negative in this zero-sum context by advantaging some racial groups at the expense of others” [5]. This claim is true insofar as it pertains to the intentional creation of majority minority districts.
Firstly, it is imperative to define what a majority minority district is. A majority minority district is a congressional voting district in which a particular racial or ethnic group makes up the majority of the constituents [6]. The legal basis for majority minority districts is derived from section 2 of the Voting Rights Act of 1965 as they are intended to amplify the voices and representation of underrepresented groups. Proponents argue that majority minority districts are essential to address the modern day impacts of historical disenfranchisement. However, by their very nature, intentionally drawing majority minority districts is contradictory to the notion of true voting equality.
In order to achieve the fairest voting districts possible, states must be blind to race when drawing congressional districts. Majority minority districts intentionally create areas in which some racial groups are almost guaranteed to have their preferred candidate elected at the expense of others in that district whose voices go unheard. Majority minority districts thus directly contrast with the 14th amendment, which affords all Americans “equal protection of law” [7]. Americans cannot all be afforded equal protection of the law if the law treats people differently through the lens of race. The logic behind majority minority districts inherently relies on the use of race when drawing district lines, which is unconstitutional no matter which race the state attempts to draw the map in favor of.
Another concerning effect of majority minority districts is their ability to be manipulated for partisan purposes. In the modern day, it is often Democrats who push for the creation of majority minority districts whereas Republicans campaign for their abolition [8]. In the past, however, it was the opposite. This is because political parties will always argue for whatever advantages their own interests, irrespective of constitutional or ethical concerns. Whichever current political party maintains the favor of minorities at any given point in time will argue for the creation of majority minority districts, and the opposing party will argue for their destruction. Thus, majority minority districts serve in part as a political tool to advance the interests of parties rather than the people their creation is allegedly meant to serve. This notion was outlined in the Louisiana case through a brief on behalf of the supporting appellees stating that Louisiana’s newest map “is far more likely to reflect political motives than racial ones” [9].
Limiting the power of racial consideration in map drawing is not unprecedented either. Cases like Shaw v. Reno have already constrained the ability to draw majority minority districts in scenarios in which such districts become unreasonable in their shape and construction [10]. Furthermore, the Supreme Court has set an applicable precedent in using the equal protection clause to strike down similar race conscious programs, such as affirmative action in college admissions [11]. Thus, it is only logical that the Court uses this argument to remove the use of race in creating electoral districts.
It is important to note that removing the intentional creation of majority minority districts does not mean the US should ignore race entirely when examining voting districts. Race is still an important lens through which we must view and evaluate our society. Any district that is intentionally discriminatory, such as districts designed to split up or overly consolidate a particular racial or ethnic group, are morally wrong and unconstitutional. However, this same logic applies to the inverse situation: any district that intentionally splits up or consolidates white voters to allow for majority minority districts must likewise be seen as unconstitutional.
The Supreme Court is currently hearing arguments on Louisiana v. Callais and is set to decide on a verdict in 2026. When they do so, they should recognize not only the unconstitutionality of intentionally creating majority minority districts but also the injustice of doing so. Rather than safeguarding the interests of minority voters, as advocates suggest, these districts only serve to promote more division by overrepresenting certain groups, underrepresenting others, and allowing for the advancement of partisan agendas. It is time for the Court to recognize the need for congressional maps to be drawn entirely race blind, treating every American as they are: complete equals under the law.
Works Cited
[1] “Louisiana v. Callais.” Oyez. Accessed October 19, 2025. https://www.oyez.org/cases/2025/24-109.
[2] Supplemental Brief for Robinson Appellants, Louisiana v. Callais, No. 24-109
[3] U.S. Congress. Voting Rights Act of 1965. Public Law 89-110. U.S. Statutes at Large 79 (1965): 437–446.
[4] “Allen v. Milligan.” Oyez. Accessed October 28, 2025. https://www.oyez.org/cases/2022/21-1086
[5] Supplemental Brief for Appellant, Louisiana v. Callais, No. 24-109
[6] Fields, Gary. “Why a Supreme Court Case from Louisiana Will Matter for the Future of the Voting Rights Act.” AP News, October 15, 2025. https://apnews.com/article/voting-rights-race-supreme-court-louisiana-edf6db57eb13c6763cf7741af8267fa6.
[7] US Constitution, amend. 14
[8] Quinn, Melissa. “Supreme Court Conservatives Appear Open to Weakening Voting Rights Act in Louisiana Congressional Map Case.” CBS News, October 15, 2025. https://www.cbsnews.com/news/supreme-court-louisiana-congressional-map-arguments-voting-rights-act/.
[9] Supplemental Brief for the United States as Amicus Curiae Supporting Appellees, Louisiana v. Callais, No. 24-109
[10] “Shaw v. Reno” Oyez. Accessed October 28, 2025. https://www.oyez.org/cases/1992/92-357
[11] “Students for Fair Admissions v. President and Fellows of Harvard College.” Oyez. Accessed October 28, 2025. https://www.oyez.org/cases/2022/20-1199
Policy & Political Review 
