Louisiana v. Callais and Further Redistricting

Action: On April 29, the Supreme Court issued its decision in Louisiana v. Callais, addressing how states may consider race when drawing congressional district maps. In a 6-3 decision, the Court held that Louisiana’s map was a racial gerrymander violating the Equal Protection Clause of the Fourteenth Amendment.¹ The Court concluded that the Voting Rights Act did not require the legislature to draw an additional majority-Black district and therefore that Louisiana could not use race in drawing the map.

Trusted Insights for What’s Ahead^®

• A group of voters who described themselves as “non-African American” had challenged the map as an unconstitutional racial gerrymander; the decision leaves in place a lower court ruling.
• While the Justices declined to strike down Section 2 of the Voting Rights Act as Louisiana and the challengers had asked, the ruling significantly limits how Section 2 can be used in practice. Going forward, a state’s map may only be challenged where racial discrimination can be proven.
• Writing for the majority, Justice Alito stated that Section 2 does not require abandonment of the Gingles test (based on the 1986 case of Thornburg v. Gingles),² that courts use to determine whether a map violates Section 2 by diluting the power of minority voters. Justice Alito pointed to the “increased use of computers in drawing districts” and suggested that plaintiffs drawing a map should be able to provide an alternative map demonstrating that an additional majority-minority district can be drawn while still meeting a state’s legitimate redistricting objectives.³
• Justice Alito emphasized that the Gingles test requires challengers to prove that “voters engage in racial bloc voting that cannot be explained by partisan affiliation.” He noted that in a state in which race is strongly correlated with party preference, “a litigant can easily exploit §2 for partisan purposes by “repackag[ing] a partisan-gerrymandering claim as a racial-gerrymandering claim.”
• Some states have already begun responding to the ruling. In Alabama, officials have filed emergency motions and are considering legislative action.⁴ Louisiana will hold a special legislative session to redraw the map. Other states may revisit existing maps before the midterm elections, while the decision raises the legal threshold for future Voting Rights Act challenges for 2028.
• What this means for business: Redistricting outcomes can shape the legislative and regulatory environment affecting businesses across sectors.
  • Companies should monitor state redistricting activity, as updated district maps may affect political representation, policy priorities, and stakeholder alignment. Changes in district boundaries can influence election results, affecting the trajectory of legislation.
  • Organizations’ government affairs or public policy functions may wish to reassess engagement strategies in response to updated district maps, as worksites may now fall in a different district unfamiliar with the organization or its industry.
  • Businesses with distributed workforces may consider how to communicate changes in congressional districts to employees.
  • Multi-state businesses should track jurisdiction-specific developments, as implementation and litigation responses may vary across states.