Allen v. Milligan

Majority reasoning

The Court held that Alabama is likely to succeed on the merits of its appeal under the updated standards set in Louisiana v. Callais, which requires that a plaintiff's proposed alternative map must perform just as well as the state's map on all of the state's legitimate redistricting goals — including keeping the Gulf Coast community together and avoiding pairing incumbents — before a Voting Rights Act violation can be found. The Court reasoned that the district court failed to apply this standard because the plaintiffs' alternative map did not meet those criteria equally well. The Court also found that the district court improperly treated Alabama's legal disagreement with the earlier court order as evidence of intentional racial discrimination, rather than applying the required presumption that legislatures act in good faith. Additionally, the Court cited the well-established principle that federal courts should not change election rules close to an election, and concluded that the state — not the courts — should decide whether last-minute map changes are in its interest.

Dissent reasoning

The dissent argued that the district court's finding of intentional racial discrimination under the Fourteenth Amendment — a separate legal claim from the Voting Rights Act claim — was not touched by Callais, which addressed only what the Voting Rights Act requires, not what the Constitution forbids. Justice Sotomayor wrote that the district court carefully applied the presumption of legislative good faith, bent over backwards to give Alabama every benefit of the doubt, and still found overwhelming evidence that Alabama deliberately made it mathematically impossible to draw a second district giving Black voters a fair opportunity to elect their preferred candidate. The dissent also argued that the majority's invocation of the principle against last-minute election changes (the "Purcell principle") was backwards: the court-ordered remedial map had been in place for over two years and was already loaded into voter rolls, while switching to the 2023 map would require county officials to manually reassign roughly 600,000 voters in a matter of days — a task Alabama's own election director previously said takes three to four months. Finally, the dissent argued that Alabama should not be rewarded for openly defying a court order that the Supreme Court itself had affirmed, and that the Court was undermining the rule of law by allowing Alabama's deliberate noncompliance to succeed.