In Louisiana v. Callais the Supreme Court held that Section 2 of the Voting Rights Act cannot be enforced merely on disparate impact; plaintiffs must show facts giving rise to a strong inference of intentional racial discrimination. The opinion retools the Gingles tests and resolves the long‑running tension between complying with the VRA and avoiding unconstitutional race‑predominant districting.
— This recalibration will reshape redistricting litigation, state mapmaking, and political representation across the country by making it harder to win Section 2 claims based solely on outcomes.
Dan Morenoff
2026.04.30
100% relevant
The article cites the Court’s 6–3 majority in Louisiana v. Callais (majority opinion by Justice Alito) and its holding that Section 2 liability requires a strong inference of intent rather than disparate‑impact alone.
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