On April 29, 2026, the Supreme Court decided Louisiana v. Callais. Louisiana had been ordered by a federal court to draw a majority-Black congressional district. It drew one. The Court held the drawing unconstitutional and rewrote the Section 2 standard, raising the evidentiary burden for successful challenges and immunizing maps that satisfy a state’s stated partisan goals. As Justice Kagan wrote in dissent, the trap closes perfectly. States cannot draw majority-minority districts, and the mechanism that would require them to cannot be satisfied under the new standard.

Shelby County v. Holder (2013) removed Section 5 preclearance — the preventive mechanism. Callais has removed Section 2 enforcement — the remedial mechanism. Both statutory pathways to voting rights protection are now closed.