Allen v. Milligan — Voting Rights Act & Racial Gerrymandering

Allen v. Milligan, 599 U.S. 1 (2023), held that Alabama's post-2020 congressional map violated Section 2 of the Voting Rights Act of 1965 by diluting Black voting power. The 5-4 decision (with Chief Justice Roberts writing for a majority that included Justices Sotomayor, Kagan, and Jackson, and Justice Kavanaugh joining in part) reaffirmed the Thornburg v. Gingles (1986) framework as the governing test for Section 2 claims. Alabama has a population that is approximately 27% Black, heavily concentrated in the state's historical "Black Belt" region — yet after the 2020 census, Alabama drew a map with only one majority-Black district out of seven, packing and cracking Black voters to prevent a second opportunity district. Alabama's subsequent remedial map (which the state drew with still only one majority-Black district) was also struck down by the district court, and the 2024 elections ultimately saw Black voters elect Shomari Figures from the redrawn 2nd District — the first time Alabama has had two Black members in Congress simultaneously.

The Allen ruling has been largely superseded by Louisiana v. Callais, 24-109 (April 29, 2026), in which a 6-3 Court (Alito majority, Kagan/Sotomayor/Jackson dissent) held that Section 2 did not require Louisiana to create a second majority-minority district, and that the State therefore lacked a compelling interest to use race to draw one. Justice Kagan's dissent argued that the decision renders Section 2 "all but a dead letter." As of May 2026, Alabama has filed emergency motions asking the Supreme Court to lift the Allen injunction in light of Callais and let the state redistrict before the 2026 primary; the three-judge panel below denied Alabama's parallel request, saying only the Supreme Court can address the substance. The framework described below is the Allen doctrine as decided in 2023 — much of it is now in active flux.

Current Law (2026)

Legal Authority

• 52 U.S.C. § 10101 — General voting rights guarantee: prohibits denying any citizen the right to vote on account of race, color, or previous condition of servitude; bars different registration standards within the same county; authorizes the Attorney General to sue to enforce, including seeking emergency provisional relief within 10 days of a finding of racial discrimination in voting
• 52 U.S.C. § 10301 — Section 2 of the Voting Rights Act: "No voting qualification or prerequisite to voting or standard, practice, or procedure shall be imposed or applied by any State or political subdivision in a manner which results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color" — the primary anti-vote-dilution provision; Allen confirmed it applies to redistricting. A violation is established by showing the political process is not equally open — election results showing underrepresentation are evidence but not determinative, and the statute expressly does not guarantee proportional representation
• 52 U.S.C. § 10302 — Enforcement proceedings: when a court finds a Section 2 violation or the Attorney General or a private plaintiff sues under the 14th or 15th Amendment, the court may direct the Director of the Office of Personnel Management to send federal observers; the court must suspend any discriminatory test or device for the jurisdiction and duration it specifies; this was the procedural vehicle used to bring the three-judge panel review in Allen
• 52 U.S.C. § 10303 — Section 5 preclearance: required covered states and localities to obtain either a declaratory judgment from the D.C. Circuit or preclearance from the Attorney General before any voting-rule change could take effect; now effectively non-operational following Shelby County v. Holder (2013), which invalidated the coverage formula. Also establishes the bilingual-materials trigger and the "bail-out" procedure for jurisdictions with clean records
• 52 U.S.C. § 10304 — Alteration of voting qualifications: codifies that any voting rule "meant to, or that does, make it harder for people of a certain race or color to elect their preferred candidates" is treated as denying the right to vote — establishing discriminatory effect (not just intent) as actionable under the preclearance framework; cases heard by three-judge district court with direct appeal to the Supreme Court
• 52 U.S.C. § 10305 — Use of federal observers: directs the OPM Director to assign election observers when a court so orders or when the Attorney General certifies credible complaints of voting-rights violations based on race; observers may enter polling places and counting locations, investigate, and report to the Attorney General or court
• 52 U.S.C. § 10307 — Prohibited acts: makes it a crime to intimidate or coerce any voter; criminalizes false statements on registration materials; prohibits officials from refusing to allow an eligible person to vote or to count and certify that vote; criminal penalties up to $10,000 and five years imprisonment
• 52 U.S.C. § 10308 — Civil and criminal sanctions: makes it a crime to deprive rights under §§ 10301–10307; authorizes the Attorney General to seek immediate injunctive relief; empowers federal courts to order provisional ballots counted before election results are certified when observers certify within 48 hours of polls closing that eligible voters were turned away
• 52 U.S.C. § 10503 — Bilingual election requirements: requires covered jurisdictions (where a language-minority group exceeds 5% of voting-age citizens or 10,000 voting-age citizens, AND has higher-than-national illiteracy rates) to provide all election materials in the applicable minority language; coverage extends through August 6, 2032; oral assistance required where a minority language is unwritten (including many American Indian and Alaska Native languages)
• 52 U.S.C. § 10504 — Judicial relief / three-judge court: when the Attorney General finds a jurisdiction using tests or devices to block voting, suit must be brought before a three-judge district court (28 U.S.C. § 2284), with direct appeal to the Supreme Court — the same three-judge panel structure used in Allen v. Milligan
• U.S. Const. amend. XIV, § 1 — Equal Protection Clause: independent basis for racial gerrymandering claims; Shaw v. Reno (1993) and Miller v. Johnson (1995) held that racial predominance in drawing district lines triggers strict scrutiny — but Allen is a statutory Section 2 case, not a constitutional one
• U.S. Const. amend. XV, § 1 — Fifteenth Amendment: "The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude" — constitutional backdrop against which Section 2 operates
• Thornburg v. Gingles, 478 U.S. 30 (1986) — Established the three-part preconditions test for Section 2 vote dilution claims in the context of multimember districts; extended to single-member districts; reaffirmed in Allen
• Shelby County v. Holder, 570 U.S. 529 (2013) — Gutted Section 5 preclearance by invalidating the coverage formula; shifted the primary VRA enforcement mechanism from preclearance to Section 2 litigation — making Allen's reaffirmation of Section 2 more significant. See Shelby County v. Holder
• Abbott v. Perez, 585 U.S. 579 (2018) — Addressed Texas redistricting and Section 2; clarified burdens of proof in Section 2 litigation
• Rucho v. Common Cause, 588 U.S. 684 (2019) — Partisan gerrymandering is a non-justiciable political question; Allen shows that racial gerrymandering under Section 2 remains justiciable even after Rucho. See Rucho v. Common Cause and Political Question Doctrine

How It Works

Background: Alabama's Black Belt and the 2020 Redistricting

The Black Belt — a swath of Alabama's rural center historically dominated by cotton agriculture and slavery — has one of the highest concentrations of Black residents in the United States. Alabama's Black population is approximately 27% statewide, and Black voters are concentrated in the Black Belt and in Birmingham and Montgomery. Despite this demographic reality, after the 2020 census, Alabama's Republican-controlled legislature drew congressional maps that contained only one majority-Black congressional district out of seven — the 7th District, centered on Birmingham and the Black Belt, which had been held by Rep. Terri Sewell (D) and is the only district in the state that has ever elected a Black representative.

The map packed Black voters into the 7th District (which became even more heavily Black) while cracking Black Belt communities across the state's other districts in ways that diluted Black political influence. The result: despite comprising 27% of the state's population, Black voters had meaningful electoral influence in at most 1 of 7 congressional seats — roughly 14% representation.

The Section 2 Standard: Gingles and Its Three Preconditions

Section 2 of the Voting Rights Act prohibits any voting "standard, practice, or procedure" that "results in a denial or abridgement" of the right to vote on account of race. The key word is "results" — a Section 2 violation does not require proof of discriminatory intent; it requires proof of discriminatory effect or outcome.

Thornburg v. Gingles (1986) established the analytical framework. To establish a Section 2 vote dilution claim, plaintiffs must first satisfy three threshold preconditions:

First — Numerosity and compactness: The minority group must be sufficiently large and geographically compact to constitute a majority in a reasonably configured single-member district. This inquiry asks whether the minority population could plausibly be combined into a majority-minority district without violating traditional districting principles (contiguity, compactness, preserving communities of interest). A minority population that is too small or too dispersed to form a majority in any reasonably drawn district cannot establish a Section 2 claim.

Second — Political cohesion: Minority voters must vote sufficiently as a bloc — they must be politically cohesive in their electoral preferences. This is typically established through statistical analysis of voting patterns in prior elections, using ecological inference or homogeneous precinct analysis to determine the candidate preferences of minority and majority voters separately.

Third — Bloc voting by the white majority: White voters must vote sufficiently as a bloc to enable the white majority to defeat the candidates preferred by minority voters in most elections. If white voters routinely support minority-preferred candidates in sufficient numbers that minority voters can elect their candidates of choice without a majority-minority district, Section 2's concern — that minority votes are submerged in elections — is not implicated.

If all three Gingles preconditions are satisfied, courts proceed to a totality-of-circumstances analysis, considering the "Senate Factors" listed in the legislative history of the 1982 VRA amendments: the history of official discrimination in voting, the extent of racially polarized voting, the use of unusually large electoral districts, candidate slating processes, and other factors bearing on the opportunity of minority voters to participate in the political process.

Allen v. Milligan: The Court's Decision

The district court (a three-judge panel required under 28 U.S.C. § 2284 for redistricting cases) found after a merits trial that all three Gingles preconditions were satisfied and, considering the totality of circumstances, that Alabama's map violated Section 2. The court ordered Alabama to draw a new map containing a second majority-Black or otherwise effective district. Alabama immediately appealed and sought a stay pending appeal.

The Supreme Court initially granted a stay (over four dissents) to allow Alabama to use the challenged map in the 2022 elections. Then, in Allen v. Milligan, the Court affirmed the district court's Section 2 finding on the merits.

Chief Justice Roberts's majority opinion (joined in full by Sotomayor, Kagan, and Jackson, and joined in part by Kavanaugh — Kavanaugh did not join Part III-B-1 on Alabama's proposed change to the first Gingles precondition, which therefore had only plurality support) made three key rulings:

First — The Gingles framework survives: Alabama had urged the Court to substantially revise or abandon Gingles, arguing that requiring states to draw majority-minority districts constitutes impermissible racial sorting in violation of the Equal Protection Clause. The majority rejected this argument. Gingles has been the governing framework for four decades; it represents Congress's considered judgment about how to implement Section 2; and it does not require or encourage racial proportionality. The Gingles preconditions ensure that Section 2 claims arise only where there is a genuine possibility of an effective minority district, not wherever minority voters are underrepresented.

Second — Race-neutral criteria cannot override Section 2 compliance: Alabama argued that it had drawn maps using race-neutral criteria and that requiring it to consider race in drawing a second majority-Black district would constitute impermissible racial gerrymandering under the Equal Protection Clause. The Court rejected this framing. Section 2 requires states to draw maps that give minority voters an equal opportunity to elect candidates of their choice; compliance with Section 2 is itself a compelling governmental interest that permits race-consciousness in redistricting. Using race to comply with the VRA is categorically different from using race to harm minority voters.

Third — The district court's findings were supported: The majority found that the district court's factual findings on the Gingles preconditions and totality of circumstances were supported by the evidence and were not clearly erroneous. Alabama's Black Belt is a genuine community of interest; the political cohesion and bloc voting findings were based on robust statistical evidence across many elections.

Justice Kavanaugh's concurrence: Kavanaugh joined the majority but wrote separately to emphasize that the Court was not endorsing proportional representation — Section 2 does not require that minority voters' representation in Congress be proportional to their share of the population. The decision is about ensuring that minority voters have an equal opportunity to elect candidates of their choice, not guaranteeing equal outcomes.

Justice Thomas's dissent (joined by Alito, Gorsuch, and Barrett): Thomas argued that Section 2 of the Voting Rights Act, as applied to require race-conscious remedial districts, is unconstitutional under the Equal Protection Clause — that Congress lacks the power under Section 5 of the Fourteenth Amendment to require states to sort voters by race in redistricting. Thomas would have held Gingles wrongly decided and Section 2's application to single-member districts unconstitutional.

Alabama's Defiance and the 2024 Remedy

The aftermath of Allen was contentious. Rather than drawing a map with a second majority-Black district as required, Alabama's legislature enacted a remedial map in 2023 that again contained only one majority-Black district (47.3% Black in the contested district). The district court found this map also violated Section 2 and appointed a special master to draw a new map. The resulting court-ordered map created a second effective majority-minority district. In the November 2024 elections, voters in the redrawn 2nd District elected Shomari Figures, a Democrat and former Biden administration official, with 54.5% of the vote — the first Black congressman from Alabama outside the 7th District in modern history. Figures joined Rep. Terri Sewell (D, AL-07), giving Alabama two Black members of Congress simultaneously for the first time.

Alabama's defiance generated significant attention and commentary about states' willingness to comply with judicial orders in voting rights cases. The episode illustrated both the importance and the practical limits of Section 2 litigation — and set up the 2026 confrontation in which Alabama is seeking to undo the Allen remedy following Callais (see Subsequent Treatment, below).

Relationship to Constitutional Racial Gerrymandering Claims

Section 2 litigation under the VRA and constitutional racial gerrymandering claims under the Equal Protection Clause are distinct but interact. The constitutional doctrine — Shaw v. Reno (1993), Miller v. Johnson (1995) — prohibits drawing district lines where race is the predominant factor, even to benefit minority voters. This creates tension: Section 2 may require drawing districts with particular racial compositions, while the Constitution limits excessive racial sorting.

The Court has managed this tension by treating VRA compliance as a compelling governmental interest that can justify race-consciousness in redistricting, provided the state does not go further than the VRA requires. The Gingles test's requirement that minority voters be geographically compact — that a majority-minority district could be drawn without contorting district lines — limits the extent of permissible racial sorting.

How It Affects You

State Variations

Section 2 of the Voting Rights Act applies nationwide — to all states and political subdivisions — without the geographic coverage limitations that made Section 5 preclearance vulnerable in Shelby County. All states are subject to Section 2 litigation.

States most active in Section 2 redistricting litigation: Following the 2020 census, Section 2 challenges were filed in Alabama (Allen), Georgia, Louisiana, North Carolina, South Carolina, Texas, and other Southern states with significant minority populations and histories of racially polarized voting. Louisiana's case — Ardoin v. Robinson — presented nearly identical facts to Allen (27% Black population, only one majority-Black congressional district out of six). After Allen, the Supreme Court vacated and remanded the Louisiana case; the state was ultimately required to draw a second majority-Black district for 2024.

State Voting Rights Acts: Several states have enacted their own voting rights laws, sometimes providing broader protections than federal Section 2. California's FAIR MAPS Act and California Voting Rights Act, New York's John Lewis Voting Rights Act (2022), and Virginia's Voting Rights Act (2021) all provide state-law Section 2 equivalents, often with lower proof thresholds (California's CVRA does not require Gingles compactness in the same way) or easier access to courts.

Local redistricting: Section 2 applies not only to congressional and state legislative districts but also to county commission districts, school boards, city councils, and other local governing bodies. Local Section 2 cases — often involving Hispanic or Black communities in smaller cities and counties — are more numerous than congressional cases and represent the majority of VRA Section 2 litigation.

Native American voting rights: Section 2 has been a significant tool for Native American voting rights in states like Montana, North Dakota, South Dakota, and Alaska, addressing at-large voting systems, polling place access, and redistricting that dilutes Native voting power on reservations and tribal lands.

Pending Legislation

• HR 14 / S 2523 — John R. Lewis Voting Rights Advancement Act of 2025 (119th Congress): HR 14 introduced March 5, 2025 by Rep. Terri Sewell (D-AL-7) — the same representative from Alabama's only majority-Black congressional district whose case prompted Allen; S 2523 introduced July 29, 2025 by Sen. Dick Durbin (D-IL). Would expand Section 2, add practice-based preclearance for election changes with a new coverage formula, increase transparency, and boost federal enforcement to protect minority and Tribal voters. Status: introduced in both chambers; no floor votes in the 119th Congress. Without enactment, Section 2 litigation remains the primary (and increasingly weakened) VRA enforcement tool following Callais.
• HR 7375 — End Prison Gerrymandering Act (119th Congress): Would count incarcerated people at their pre-incarceration residence for Census purposes and require states to use that residence for congressional redistricting starting in 2030. Addresses a separate form of vote dilution — packing incarcerated populations (disproportionately Black and Hispanic) into rural districts where they cannot vote, inflating rural district populations for redistricting purposes. Status: introduced.
• HR 5921 — Redistricting Transparency and Accountability Act of 2025 (119th Congress): Would require nationwide public websites, hearings, and open data so communities can track and participate in how congressional districts are drawn. Would not change the substantive Section 2 standard but would improve public access to the redistricting process. Status: introduced.
• Native American Voting Rights Act: Periodically introduced to address specific access barriers facing tribal voters (distance from polling places, lack of residential street addresses, restrictions on voter ID using tribal identification).
• Redistricting reform proposals: Various proposals for independent redistricting commissions at the federal and state level would change the institutional setting in which redistricting occurs; Section 2 compliance requirements apply regardless of whether commissions or legislatures draw maps.

Recent Developments

• 2023 — Allen v. Milligan decided: The Supreme Court's 5-4 decision reaffirmed Section 2 and the Gingles framework. Alabama was ordered to draw a second majority-Black congressional district.
• 2023 — Alabama defiance: Alabama's legislature drew a remedial map that still lacked a second majority-Black district; the district court rejected it and appointed a special master.
• 2023 — Ardoin v. Robinson (Louisiana): Following Allen, the Supreme Court vacated and remanded Louisiana's parallel case; Louisiana ultimately was required to create a second majority-Black congressional district.
• 2024 — Remedy maps in use: Court-ordered maps in Alabama and Louisiana enabled Black voters to elect candidates of their choice from second congressional districts in the November 2024 elections.
• 2024 — Alexander v. South Carolina State Conference of the NAACP: The Supreme Court addressed the intersection of racial and partisan gerrymandering claims — when a legislature argues it drew maps based on political affiliation rather than race, courts must determine which was the predominant factor. The decision raised the evidentiary bar for proving racial predominance, creating new challenges for plaintiffs.
• April 29, 2026 — Louisiana v. Callais, 24-109: A 6-3 Supreme Court (Alito majority, joined by Roberts, Thomas, Gorsuch, Kavanaugh, and Barrett; Kagan dissenting joined by Sotomayor and Jackson) held that Section 2 did not require Louisiana to create a second majority-Black district, and that the State therefore had no compelling interest to use race in drawing one. Justice Kagan's dissent: the decision renders Section 2 "all but a dead letter." Civil rights organizations have characterized the ruling as having "eviscerated" the VRA.
• April–May 2026 — Alabama seeks to undo the Allen remedy: Following Callais, Alabama Attorney General Steve Marshall filed emergency motions with the U.S. Supreme Court asking it to lift the Allen v. Milligan injunction and let Alabama redistrict before the 2030 census. A three-judge district court panel denied a parallel state request in late April 2026, holding that "[o]nly the Supreme Court has the authority to address the substance of those arguments." Justice Thomas set a response deadline of May 2026 with the State seeking a stay by May 14 ahead of the May 19 primary. The future of the second AL-02 majority-Black district is in active doubt.
• April 29–30, 2026 — Political reactions to Callais: President Trump praised Justice Alito as "brilliant" for authoring the majority opinion, calling the decision "a BIG WIN for Equal Protection under the Law." House Speaker Mike Johnson (R-La.) publicly urged other states to redraw their congressional maps in the wake of the ruling. The NRCC called it "a victory for the Constitution." Sen. Chuck Schumer (D-N.Y.) called the ruling "awful"; Sen. Raphael Warnock (D-Ga.) called it "Jim Crow in new clothes"; Rep. James Clyburn (D-S.C.) said Roberts would "join the ranks of infamous justices." Louisiana Gov. Jeff Landry signed an executive order the following day suspending Louisiana's May 16 House primary elections to allow time to redraw maps — though he kept the Senate primary on schedule, drawing criticism from Sen. Bill Cassidy (R-La.). (Sources: The Hill, April–May 2026)
• May 2026 — Redistricting scramble after Callais: The Supreme Court's Callais decision triggered a national redistricting wave. Louisiana announced it would delay its congressional primaries — slated to begin in June 2026 — to redraw maps after Callais removed the second majority-Black district requirement. House Minority Leader Hakeem Jeffries announced Democrats were devising redistricting strategies in New York in response. Florida began pursuing new congressional maps. (Sources: The Hill, Politico, May 2026)
• May 7–8, 2026 — Tennessee redistricting, Section 2 implications: Tennessee's Republican-controlled legislature proposed a new congressional map designed to give the GOP a clean sweep of all nine of the state's congressional districts by fracturing the Black-majority Memphis area across three separate districts — a classic "cracking" strategy. Civil rights advocates indicated the map would face Section 2 scrutiny, but the Callais decision substantially raised the bar for such challenges. (Sources: Politico, May 2026)
• May 9–11, 2026 — Virginia redistricting upheaval: The Virginia Supreme Court struck down a Democrat-backed redistricting referendum that would have expanded Democrats' expected edge in the state from 6-5 to 10-1. The ruling eliminated four House seats expected to flip Democratic, dealing a setback to Democrats' prospects of retaking the House in fall 2026. Sen. Mark Warner called the decision a defeat for the will of Virginia voters; President Trump celebrated the ruling. The episode illustrates how redistricting and voting rights are converging ahead of the 2026 midterms. (Sources: The Hill, May 2026)

Subsequent Treatment

Allen v. Milligan remained good law from June 2023 until April 29, 2026, when Louisiana v. Callais substantially narrowed the holding. While Allen has not been formally overruled, Callais held that Section 2 does not compel the creation of additional majority-minority districts in the way Allen had been understood to require, and that race-conscious redistricting to comply with such a reading lacks a compelling governmental interest under the Equal Protection Clause. Practically, the Gingles preconditions still exist as a doctrinal framework, but the proof burden and the available remedy have both contracted significantly. Lower courts and litigants are now reading Allen through the lens of Callais: prior Section 2 victories that ordered the creation of new majority-minority districts are vulnerable to challenge, and the Alabama injunction that produced the AL-02 district is itself subject to active reconsideration before the Supreme Court.

FAQ

What did Allen v. Milligan decide? The Supreme Court held 5-4 in June 2023 that Alabama's post-2020 congressional map violated Section 2 of the Voting Rights Act by diluting Black voting power. Alabama drew only one majority-Black district out of seven despite having a 27% Black population. The Court reaffirmed the Thornburg v. Gingles (1986) three-part test as the governing framework for Section 2 vote-dilution claims.

What is the Gingles test? Gingles sets three preconditions for a Section 2 vote-dilution claim: (1) the minority group is large enough and geographically compact enough to form a majority in a reasonably drawn single district; (2) the minority group votes cohesively; and (3) white voters vote as a bloc and usually defeat minority-preferred candidates. If all three are satisfied, courts then weigh the "totality of circumstances" using the Senate Factors.

Is Allen v. Milligan still good law? As of May 2026, Allen has not been formally overruled, but Louisiana v. Callais (April 29, 2026) substantially narrowed its reach. A 6-3 Court held that Section 2 did not require Louisiana to create a second majority-Black district, and that using race to do so lacked a compelling interest. Alabama has asked the Supreme Court to lift the Allen injunction entirely. The doctrine is in active flux.

Does Section 2 of the VRA require proportional representation? No. Both the Allen majority and Justice Kavanaugh's concurrence were explicit: Section 2 guarantees minority voters an equal opportunity to elect candidates of their choice — it does not guarantee seats proportional to population share. A state with 27% Black residents is not automatically required to give Black voters 27% of congressional districts; the Gingles analysis must show that a majority-minority district is feasible and that existing maps dilute minority voting power.

What happened in Alabama after the ruling? Alabama's legislature defied the order and drew a remedial map that still had only one majority-Black district. The district court rejected it and appointed a special master to draw a new map. The court-drawn map created a second effective minority district, and in November 2024, Shomari Figures won that seat — the first time Alabama sent two Black members to Congress simultaneously. After Callais, Alabama is now seeking to undo that remedy before the 2026 primaries.

What's the John Lewis Voting Rights Advancement Act? Introduced repeatedly in Congress (passed the House but not the Senate), this legislation would restore federal preclearance requirements — requiring covered jurisdictions to obtain federal approval before changing voting laws — using an updated coverage formula. Without it, Section 2 litigation remains the primary federal voting-rights enforcement tool: slower, more expensive, and available only after discriminatory maps have already been used in elections.

How does Section 2 differ from Section 5? Section 5 was the preclearance requirement — states with a history of discrimination had to pre-approve any voting changes with the federal government before they took effect. Shelby County v. Holder (2013) effectively invalidated Section 5 by striking its coverage formula. Section 2 is a nationwide, after-the-fact lawsuit mechanism: plaintiffs must sue after a map is enacted, prove the Gingles preconditions, and win in court — a process that often takes multiple election cycles.