Allen v. Milligan and Predicting Louisiana v. Callais

In its 2021 docket, the United States Supreme Court would take on the case Allen v. Milligan from the Eleventh Circuit in the United States Court of Appeals. This case surrounded the new Congressional map that Alabama had drawn following the 2020 Census, which would be in effect from the 2022 House of Representatives Elections until 2030. In this map, a single majority-minority district was drawn of the seven total, despite nearly 1 in 3 Alabamians belonging to a racial minority. Voters and several organizations would challenge this new Congressional map on the grounds of it violating Section 2 of the Voting Rights Act of 1965, which prohibits “voting practices or procedures that discriminate on the basis of race, color, or membership in one of the language groups identified in Section 4 of the Act.” (United States Dept. of Justice, “Section 2 of the Voting Rights Act”, 2023). Prior to the decision in Allen v. Milligan, Alabama and many other southern states would often do the bare minimum regarding the creation of majority-minority congressional districts. For the entirety of Alabama’s post-1964 congressional history, the state had drawn a single majority-minority Congressional district. Many other states, such as Louisiana and South Carolina, would also draw single majority-minority districts, despite their population balances being slightly more diverse than Alabama. Additionally, since 1992 Alabama’s congressional map contained a near-unchanging district configuration, with a single minority-packed district that included black neighborhoods of 2 Birmingham, Montgomery, and rural “black belt” counties (Lewis et. al, “U.S. Congressional District Shapefiles”, 2025).