Allen v. Milligan
Headline: High Court upholds block on Alabama’s 2022 congressional map, finding it likely violates the Voting Rights Act and forcing courts to consider a second majority‑Black district before elections proceed.
Holding: The Justices affirmed that Alabama’s enacted congressional plan likely violates Section 2 of the Voting Rights Act and upheld a lower court injunction stopping the State from using the map in upcoming elections.
- Prevents Alabama from using HB1 for upcoming federal elections.
- May force a new map that produces a second majority-Black district.
- Shapes how courts use racial data and computer simulations in voting cases.
Summary
Background
A group of Alabama citizens, civil-rights lawyers, and a state legislator sued after the Alabama Legislature adopted a new congressional map called HB1 for the 2022 elections. HB1 closely resembled the prior map and produced only one district where Black voters were a majority of the voting-age population. Plaintiffs argued HB1 illegally reduced Black voters’ opportunity to elect candidates of their choice under Section 2 of the Voting Rights Act and also raised Equal Protection claims. A federal three-judge court preliminarily enjoined Alabama from using HB1 for upcoming elections.
Reasoning
The Supreme Court reviewed whether plaintiffs met the three Gingles preconditions (a suitably compact majority for an additional district, political cohesion, and racially polarized voting) and whether, under the totality of circumstances, HB1 left minority voters less able to elect their preferred candidates. The Court agreed that plaintiffs met those tests based on expert maps, voting data showing strong racial bloc voting, and Alabama’s documented history. The Court rejected Alabama’s proposal to use a computer-generated race‑neutral benchmark to measure liability and declined to rewrite longstanding Section 2 precedent. The opinion held Section 2 applies to single‑member districts.
Real world impact
The ruling leaves the preliminary injunction in place and prevents Alabama from using HB1 in forthcoming federal elections while the litigation continues. It means courts can require new mapmaking that can create a second district where Black voters could form a majority, if that outcome meets traditional redistricting criteria. The decision will influence how states, mapmakers, and courts treat racial data, illustrative maps, and computer simulations in Voting Rights Act challenges.
Dissents or concurrances
Justice Kavanaugh joined the majority in part but wrote separately about stare decisis and statutory interpretation. Justices Thomas and Alito wrote dissents arguing the Court misapplied Section 2, warned against race‑based redistricting, and would have rejected the injunction; other Justices joined portions of those dissents. Those opinions stress constitutional limits on race‑conscious mapmaking.
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