Allen v. Milligan
Headline: Voting map ruling upholds court finding that Alabama’s new congressional map likely violates the Voting Rights Act, blocking its use and preserving the possibility of a second majority‑Black district that affects statewide voters.
Holding: The Court affirmed that plaintiffs were likely to succeed under Section 2 of the Voting Rights Act, agreeing Alabama’s 2022 congressional map likely dilutes Black voters’ ability to elect a second representative, and thus the map must be blocked.
- Blocks Alabama from using HB1 in upcoming congressional elections pending further proceedings.
- Keeps open possibility of a second majority-Black congressional district in Alabama.
- Shifts focus to state redistricting and further court actions over final map.
Summary
Background
The dispute involved Alabama’s 2022 congressional map (HB1) and three groups of Alabama residents who sued to stop elections under that map. The plaintiffs argued HB1 diluted Black voters’ ability to elect representatives. A three‑judge District Court held a lengthy hearing and preliminarily enjoined the State from using HB1. The State appealed to this Court, which reviewed the District Court’s findings and issued a decision in June 2023.
Reasoning
The Court applied the familiar three‑step framework from Thornburg v. Gingles. It found plaintiffs met the first step by showing illustrative maps that could reasonably produce a second majority‑Black district without obvious rule violations. The Court also found evidence of strong racial voting polarization and other circumstances showing Black voters have less opportunity to elect their preferred candidates. The Court rejected Alabama’s proposed “race‑neutral benchmark” test and declined to rewrite §2 of the Voting Rights Act. It also concluded §2 applies to single‑member congressional districts and that the District Court correctly found a reasonable likelihood of plaintiffs’ success.
Real world impact
The ruling affirms the preliminary injunction and stops Alabama from using HB1 while the litigation continues. The decision keeps in play remedial map options that could create a second majority‑Black district and signals courts will weigh local voting patterns, history, and practical map designs when applying §2. The ruling is not necessarily the final map or last word and could change on further proceedings.
Dissents or concurrances
Justices wrote separately. One Justice concurred in part; others dissented, arguing the Court should demand a different, race‑neutral benchmark or that §2 should not be read to require race‑based redistricting in single‑member districts.
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