Louisiana eliminates second majority-Black district after VRA ruling

The became law on August 6, 1965, after President Lyndon B. Johnson signed it at the U.S. Capitol with civil rights leaders including Rev. Martin Luther King Jr., Rosa Parks, and Rep. John Lewis in attendance. Johnson drafted the bill in direct response to the March 7, 1965, attack on peaceful marchers by Alabama state troopers at the Edmund Pettus Bridge in Selma, telling Attorney General Nicholas Katzenbach to write the toughest voting rights law possible. The House passed it 328 to 74 and the Senate passed it 79 to 18, with bipartisan support from Senate Majority Leader Mike Mansfield (D-MT) and Senate Minority Leader Everett Dirksen (R-IL). Section 2 prohibited any voting rule that 'results in a denial or abridgement of the right of any citizen to vote on account of race or color.' Section 5 added a preclearance requirement forcing covered Southern states to get federal approval before changing any voting law. The Supreme Court gutted Section 5 preclearance in Shelby County v. Holder in 2013, which is why Louisiana's post-2020 redistricting went forward without federal pre-approval.

The Supreme Court's first major ruling on the VRA's reach came in Allen v. State Board of Elections (1969), decided just four years after the law's passage. The Court ruled 8 to 1 that Section 5 preclearance covered not just outright denial of the vote but any change in voting practice that could dilute minority voting power, including switches to at-large elections. The ruling came directly in response to Southern states adopting at-large systems after the VRA passed, specifically to neutralize Black voting strength. In Louisiana, Mississippi, and South Carolina, dozens of jurisdictions shifted to at-large elections in the late 1960s to prevent Black candidates from winning majority-Black precincts under single-member district systems. Allen established that the VRA's reach was broad enough to catch these workarounds. Three years after Allen, the Louisiana Legislature faced its first DOJ objections to statewide redistricting plans under Section 5 preclearance, beginning a pattern of federal oversight of Louisiana voting laws that lasted until Shelby County ended preclearance in 2013.

The Thornburg v. Gingles framework that Louisiana v. Callais revised was itself created only after Congress acted to reverse a Supreme Court decision. In Mobile v. Bolden (1980), the Court ruled that Section 2 required proof of intentional racial discrimination. Congress rejected that standard in the 1982 VRA amendments and added an explicit results test, making it possible to challenge voting laws that produced discriminatory outcomes without needing to prove discriminatory motive. In 1986, the Court applied that new results test for the first time in Thornburg v. Gingles, a North Carolina redistricting case. Justice William Brennan wrote the majority opinion, establishing a three-part test for vote dilution claims: the minority group must be sufficiently large and geographically compact, must vote cohesively, and must face bloc voting by the white majority that usually defeats its preferred candidates. Gingles governed Section 2 redistricting claims for 40 years before the Court revised it in Callais.

The NAACP Legal Defense Fund filed Robinson v. Ardoin in March 2022, arguing Louisiana's post-2020-census congressional map violated Section 2 by packing nearly all Black voters into a single district. Attorneys Janai Nelson (President and Director-Counsel, NAACP LDF), Tracie Washington (Louisiana Justice Institute), and ACLU counsel represented the nine individual Black plaintiffs and organizational plaintiffs including the NAACP Louisiana State Conference and Power Coalition for Equity and Justice. U.S. District Judge Shelly Dick heard a week-long evidentiary hearing and issued a preliminary injunction in June 2022, finding the map likely violated the VRA. The Supreme Court stayed that injunction pending Allen v. Milligan, the Alabama redistricting case. In June 2023, the Court ruled 5 to 4 in Allen v. Milligan that Alabama's map violated Section 2 and upheld the Gingles framework, forcing Louisiana to comply. Louisiana's legislature passed Senate Bill 8 in January 2024, creating the majority-Black 6th Congressional District. The case subsequently became Robinson v. Landry as the governorship changed, with plaintiffs still represented by the NAACP LDF and ACLU.

The 6th Congressional District that Rep. Cleo Fields won in November 2024 connected Black communities from Caddo Parish in Shreveport, where roughly 100,000 Black residents make up more than half of the parish population, south through the Red River corridor parishes of Natchitoches, Winn, and Grant, into the majority-Black neighborhoods of East Baton Rouge Parish, which has a Black population of about 240,000. The district had a Black voting-age population of approximately 54 percent, up from just 24 percent under the prior map that Judge Dick struck down. A March 2025 Power Coalition for Equity and Justice analysis found Black voter turnout in the district exceeded expectations, with newly registered voters making up a notable share of Fields' winning margin. Under SB 121, that 54 percent Black majority district is eliminated entirely, scattering those Black communities into majority-white districts.

Gov. Jeff Landry signed Senate Bill 121 into law on May 29, 2026, hours after the Louisiana Legislature gave it final passage. The Louisiana House passed it 66 to 35 on May 28, and the Senate approved the amended version the next day. Several observers in the gallery shouted 'Shame!' as the House voted and were escorted out by security. The new map redraws Rep. Cleo Fields' (D-LA) 6th Congressional District, which had run from Baton Rouge north to Shreveport, into white-majority communities concentrated around southern Louisiana. Fields won the seat in 2024 after a 28-year absence from Congress, returning when courts ordered a second majority-Black district drawn.

The redistricting follows the Supreme Court's 6 to 3 ruling on April 29, 2026, in Louisiana v. Callais. Justice Samuel Alito, appointed to the Court by President George W. Bush and confirmed 58 to 42 in January 2006, authored the majority opinion joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett. The Court found Louisiana's SB 8 map, which created two majority-Black districts, was an unconstitutional racial gerrymander because Section 2 of the Voting Rights Act didn't require it and no compelling governmental interest justified the racial classification. Justice Elena Kagan wrote the dissent, joined by Justices Sotomayor and Jackson. Kagan argued the majority had eviscerated Section 2 without any basis in the statute's text, noting Congress amended Section 2 in 1982 explicitly to prohibit results-based discrimination, not just intentional discrimination.

The Callais decision significantly reworked Thornburg v. Gingles, the 1986 framework governing minority voting rights claims. Justice Alito identified four grounds for revising Gingles: vast social change in the South since 1986; the correlation between race and party preference; partisan-gerrymandering claims being repackaged as racial ones; and advances in mapping technology. Under Callais, plaintiffs must now show evidence supporting a 'strong inference' that a state intentionally drew districts to diminish minority voting opportunity. The Congressional Research Service found that the ruling narrowed VRA Section 2 by requiring illustrative maps submitted by plaintiffs to meet all of a jurisdiction's stated political objectives, a standard that had previously been applied only in some circuits.

Louisiana becomes the second state to eliminate a majority-minority congressional district after Callais. Tennessee was first: Gov. Bill Lee signed a redistricting bill on May 7, 2026, just eight days after the ruling, splitting the state's only majority-Black 9th Congressional District, centered in Memphis, into three white-majority districts. The NAACP filed suit to block Tennessee's map the same week. The Heritage Foundation's Zack Smith, senior legal fellow, called Callais a win, stating it corrected courts' misinterpretations of the Voting Rights Act that purported to require states to draw congressional districts based on race. Democracy Docket's Marc Elias described it as a ruling that cleared the path for states to gerrymander mid-election.

The ACLU, NAACP Legal Defense Fund, and Brennan Center for Justice called on Louisiana lawmakers to amend the bill before passage, arguing it drastically diminishes representation for Black voters and mirrors the pre-2022 map that federal courts struck down as discriminatory. The ACLU of Louisiana said the ruling undermined one of the last remaining tools that protected voters from racial discrimination in redistricting. The Supreme Court had given Callais immediate effect in a subsequent order, blocking lower courts from using prior VRA standards to halt new maps as states rushed to redraw boundaries ahead of the 2026 midterm elections.

Under the new map, the single surviving majority-Black district runs from New Orleans into portions of Baton Rouge and will likely put Democratic Reps. Cleo Fields and Troy Carter in the same district for the November 2026 elections. Republicans currently hold four of Louisiana's six House seats; the new map is projected to give them five, leaving Democrats one. Louisiana's Republican-controlled legislature moved quickly once Landry delayed the May 16 primary election. Tens of thousands of voters had already returned mail ballots before the delay was announced, drawing an emergency legal challenge from civil rights groups who said suspending an active election was improper.

Nationally, voting rights scholars and civil rights organizations warn the Callais standard may open majority-minority districts in other states to legal challenge. Any district drawn to comply with prior Section 2 orders could now be challenged as a racial gerrymander under the new proof standards. The Brennan Center for Justice documented that states beyond Louisiana and Tennessee, including states with court-ordered majority-minority districts in Alabama, Georgia, and South Carolina, face potential redistricting challenges in the months before the 2026 midterms. Campaign Legal Center described the ruling as one that eviscerated the Voting Rights Act and projected that minority representation in Congress could decline further if states act quickly before midterm primaries.

The midterm election calendar added urgency to Louisiana's redistricting timeline. With congressional primaries originally scheduled for May 16, 2026, and early voting already underway when Landry delayed the election, the legislature had a narrow window to pass a new map before November. Democracy Docket tracked the signing and immediately flagged anticipated lawsuits, noting that voting rights groups retain the ability to challenge maps under the Fourteenth and Fifteenth Amendments even after Callais narrowed Section 2 remedies. The Democracy Docket Louisiana case tracker logs all active litigation over the state's congressional maps in real time.