Supreme Court Ruling in Callais Case Effectively Kills Key Voting Rights Act Provision, Paving Way for Extreme Gerrymandering

The U.S. Supreme Court’s decision in Louisiana v. Callais, issued on Wednesday, June 25, 2025, has delivered a decisive blow to a longstanding federal safeguard under the Voting Rights Act (VRA) that ensured Black and Latino voters a minimum level of representation in certain states. The ruling, authored by Justice Samuel Alito, was joined exclusively by the Court’s Republican appointees.

In Callais, the Court effectively dismantled one of the few remaining federal legal checks on gerrymandering: the VRA’s provision governing racial gerrymanders. Before the decision, this provision sometimes required states to create additional legislative districts where a racial minority group constituted a majority. The Court’s ruling neutralizes this requirement in two key ways.

Reinstatement of City of Mobile v. Bolden (1980)

First, Alito’s opinion revives the precedent set in City of Mobile v. Bolden (1980), which held that plaintiffs alleging a VRA violation must prove that state lawmakers acted with “racially discriminatory motivation.”

Congress overturned Bolden in 1982 by amending the VRA to clarify that a state law could violate federal law if it “results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color”—even without explicit racist intent. Alito disputes that his ruling repeals this 1982 amendment, but his opinion relies on a narrow and legally dubious distinction.

While Alito claims Callais “does not demand a finding of intentional discrimination,” he simultaneously asserts that the VRA “imposes liability only when the circumstances give rise to a strong inference that intentional discrimination occurred.” This effectively resurrects the Bolden standard, albeit with the addition of the phrase “strong inference.”

Partisan Gerrymandering Elevated as a Trump Card Over Racial Safeguards

Second, Alito’s opinion elevates the principle of partisan gerrymandering to a position of supremacy, overriding the VRA’s protections against racial gerrymanders. Prior to Callais, the VRA scrutinized legislative maps in states with racially polarized voting patterns—where white voters predominantly supported Republicans and non-white voters leaned toward Democrats.

Without the VRA’s oversight, these states could use race as a proxy to identify Democratic voters and draw maps that minimized non-white representation in state legislatures or Congress. The Court’s decision in Callais removes this federal safeguard, leaving racial minorities vulnerable to systemic disenfranchisement through partisan-driven redistricting.

“Callais is a cry of devotion to the idea that state lawmakers should be allowed to draw legislative maps that benefit their own political party, and that lock the opposing party out of power to the maximum extent possible.”