Allen v. Milligan: Supreme Court Upholds VRA Section 2, Orders Second Black District

The Supreme Court ruled 5-4 in Allen v. Milligan that Alabama's congressional map violated Section 2 of the Voting Rights Act by failing to create a second majority-Black district. Chief Justice Roberts wrote the majority opinion reaffirming the Thornburg v. Gingles three-precondition framework and rejecting Alabama's argument that race-neutral redistricting principles were sufficient. Justice Kavanaugh joined Roberts and the three liberal justices, making this the most significant VRA ruling in a decade. The Court ordered Alabama to redraw its map to create an additional Black opportunity district.