After three separate federal courts held that Louisiana’s prior congressional map likely violated Section 2 of the Voting Rights Act, which prohibits states from diluting the voting strength of voters of color, the Louisiana state legislature enacted its current congressional map—SB8—to redress that violation, while also accomplishing other political objectives. The United States District Court for the Western District of Louisiana, however, held the Legislature’s actions unconstitutional and enjoined the new redistricting plan, concluding that its decision to create a second majority Black district—as required by Section 2—while furthering other permissible redistricting goals resulted in a racial gerrymander. Press Robinson and other voters of color (who had successfully challenged Louisiana’s original map under Section 2) and the State of Louisiana appealed the decision, asking the Supreme Court to reverse the district court’s ruling. 

In December 2024, CAC filed an amicus brief urging the Supreme Court to uphold Louisiana’s remedial map. Our brief explains that the district court’s decision is contrary to Supreme Court precedent and undermines effective enforcement of Section 2 and the Fifteenth Amendment.   

As we detail in our brief, the district court’s conclusion that SB8 is a racial gerrymander is irreconcilable with Supreme Court precedent. The court made three fundamental errors in its racial gerrymandering analysis and thereby usurped the Legislature’s prerogative to use its broad discretion to enact its preferred remedial map.  

First, the court below incorrectly treated the Legislature’s stated intention to create a second majority Black district as virtually decisive evidence of racial predominance. If the district court were right, then any remedial map drawn by a state legislature in response to judicial findings of a Section 2 violation would trigger strict scrutiny. That is plainly incorrect and would upend the Supreme Court’s well-settled Voting Rights Act jurisprudence, which requires states to take account of race to ensure fair maps which give citizens of all races equal opportunity to elect candidates of their choice. Second, the district court discredited the valid political considerations that motivated the Legislature’s enactment of SB8 and frustrated the Legislature’s ability to advance its own non-remedial interests when drawing Section 2-compliant districts. Finally, the district court erroneously required SB8 to meet the Gingles requirements, which concern requirements for Section 2 liability, but are irrelevant to the lawfulness of a remedial map. 

The district court’s decision also thwarts Section 2’s ability to enforce the guarantees of the Fifteenth Amendment. By prohibiting maps that dilute the voting strength of communities of color, Section 2 enforces the Fifteenth Amendment’s ban on racial discrimination in voting and thereby strengthens our nation’s multiracial democracy. Here, the district court’s rejection of a legislatively-enacted map designed to remedy vote dilution undercuts the effective enforcement of Section 2 and, in turn, the Fifteenth Amendment. If left uncorrected, the district court’s ruling would make it unnecessarily difficult for jurisdictions to comply with Section 2 and substantially threaten Section 2’s ability to protect voters of color against vote dilution.