Marking a turning point in legal history, the ruling in the recent Supreme Court case Allen v. Milligan has been hailed as both “historic and significant” by Deuel Ross, the plaintiff’s attorney. On June 8, 2023, this case, which revolved around an Alabama congressional redistricting map drawn by a Republican-dominated legislature, was brought out of the lower district court. In a state where one in four voters are Black, yet only one Black representative held a position out of the seven representatives, the fairness of the district lines was under question. An analysis of the population distribution within the lines found that Black voters were dominant in one sole district, whereas the rest of the Black population was meticulously spread out in other districts. The areas with the most Black residents had more voting power than the single district, which prevented Alabama from having more than one Black representative. In Allen v. Milligan, in a 5-4 ruling, both conservative and liberal judges upheld Section 2 of the Voting Rights Act of 1965 (VRA) in an attempt to alleviate the effects of racial discrimination. The Court found that, given Alabama’s racially polarizing voting, the map had to be redrawn. Although served with a glimpse of hope, the Court declined the request from Black Alabama voters and organizations for the lines to be redrawn with the intention of having proportional Black representation. Thus, while the discriminatory effects were addressed, they were not alleviated. By using an outdated method to determine the districting of lines while viewing the Constitution as a “color-blind” document, the Court failed to fully address a critical and ongoing issue that the VRA has originally intended to solve.

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