Allen v. Milligan

In Allen v. Milligan, the U.S. Supreme Court on June 8, 2023, affirmed a lower court ruling that Alabama's 2021 congressional map likely violated Section 2 of the Voting Rights Act. The map had only one majority-Black district out of seven, despite Black residents making up about 27% of the state's population. Plaintiffs, including Evan Milligan and civil rights groups, argued that the map diluted Black voting strength. The Court, in a 5-4 decision, rejected Alabama's race-neutral interpretation and held that the state must create a second district where Black voters have an opportunity to elect their preferred candidate. This ruling preserved a key tool for challenging discriminatory redistricting plans.

The Supreme Court ruled 5-4 to uphold the lower court's preliminary injunction, requiring Alabama to redraw its congressional map to include a second majority-Black or opportunity district. Chief Justice John Roberts and Justice Brett Kavanaugh joined the liberal justices in the majority.

Whether Alabama's congressional redistricting map violated Section 2 of the Voting Rights Act by diluting the voting power of Black citizens, and whether the law requires race-conscious consideration in drawing district lines.

The decision reinforced Section 2 of the Voting Rights Act as a vital safeguard against racial gerrymandering. It had immediate effects on redistricting in Alabama and other states, particularly in the South, by affirming that minority voters must have fair opportunities to elect representatives. The ruling was viewed as a surprising but significant victory for voting rights advocates and influenced subsequent legal challenges to district maps nationwide.