The U.S. Supreme Court Decision in Louisiana v. Callais

05.28.2026

On April 29, 2026, the United States Supreme Court (“USSC”) ruled the federal Voting Rights Act (“VRA”) did not require the state of Louisiana to create an additional electoral district where a minority group makes up a majority of the population, and that, as a result, there was no compelling interest that justified the State’s use of race in creating its new congressional map. The map was ruled a deliberate, unconstitutional practice of drawing electoral district boundaries to manipulate the voting power of a specific minority group, or racial gerrymander.

In Louisiana v. Callais, after the 2020 census, the state of Louisiana was apportioned six congressional seats and its Black residents were approximately one-third of the population. The Louisiana State Legislature redrew its congressional districts so that it did not include a second majority-black district and only had one. Federal courts found that this likely violated Section 2 of the VRA because the influence of Black voters was diluted. Under threat of a court order, the State Legislature then drew a new map that contained a second Black majority district. In general, a community of minority voters must be sufficiently numerous and compact to constitute a majority in a reasonably confined district. The map drawn by the Legislature created the second majority-Black district by stretching from Baton Rouge to Shreveport, which are approximately two hundred and forty-six miles away from each other.

A group of Caucasian voters filed a lawsuit, alleging that the map was challenged as a racial gerrymander in violation of the Equal Protection Clause of the Fourteenth Amendment, as race was the reason for drawing that district that way.

The Supreme Court consolidated cases and focused on whether creating a majority-minority district as a remedy for a VRA violation violated the Fourteenth or Fifteenth Amendments. The Fifteenth Amendment provides that the “right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude.” .

In the past, the USSC had assumed that complying with the VRA provided a compelling reason that might justify the intentional use of race in drawing legislative districts. After over thirty years, the Court decided to resolve whether compliance with the VRA provides a compelling reason for race-based districting. Section 2 of the VRA in its original form closely tracked the language of the Fifteenth Amendment. Later, Section 2 was amended to include a discriminatory effects test, similar to a disparate impact test. The USSC found that no compelling interest justified the Louisiana State map, because the VRA did not require the State to create a new majority-minority district. The Court further held that a violation of Section 2 only occurs when circumstances give rise to a strong inference that intentional discrimination occurred and not when there are discriminatory effects.

In reaching its decision, the Court held that the Constitution almost never permitted a State to discriminate on the basis of race and that doing so triggered strict scrutiny. It further indicated that there are limited compelling interests that can satisfy strict scrutiny and that when Section 2 of the VRA is properly construed, it can be a limited compelling interest that satisfies strict scrutiny. The Court found that a law that seeks to enforce the Fifteenth Amendment by prohibiting “mere disparate impact” would fail to enforce a right that the Fifteenth Amendment secures.

The Supreme Court’s decision in Louisiana v. Callais was about a specific action taken by the Louisiana legislature, and did not consider the California Voting Rights Act (CVRA). It is possible that the CVRA may face future legal challenges, based on the Supreme Court’s ruling, because the CVRA mandates race-based analysis when creating voting areas.

For now, however, and unless and until it is determined otherwise by the courts, the CVRA remains in effect in California. Local agencies, including, cities, school districts, and community college districts, are encouraged to consult legal counsel regarding CVRA compliance and the potential implications of the Supreme Court’s decision.

If you have questions about the Supreme Court’s decision, please contact us.

If you have any questions about the content of this Alert or your agency’s obligations under the CVRA, please contact the authors of this Alert or your regular AALRR Counsel.

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. The applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process.