Does compliance with Section 2 of the Voting Rights Act of 1965 provide a compelling interest that justifies the intentional use of race in drawing legislative districts under the Equal Protection Clause? If so, how must Section 2 be interpreted to ensure it does not exceed Congress's enforcement power under the Fifteenth Amendment? Does Louisiana's SB8 congressional map constitute an unconstitutional racial gerrymander based on this interpretation?

• The State sought to avoid a court-mandated map that would have ousted preferred Republican incumbents.
• The creation of the second majority-black district in SB8 was intended to comply with the Voting Rights Act as interpreted by the lower court in *Robinson v. Ardoin*.
• Compliance with the Voting Rights Act should serve as a compelling interest to satisfy the strict scrutiny standard.
• The State's goal was to protect the seats of Speaker of the House Mike Johnson, House Majority Leader Steve Scalise, and Representative Julia Letlow.

• The SB8 map is an unconstitutional racial gerrymander because race predominated in the State's decisionmaking process.
• The boundaries of District 6 are irregular, stretching 250 miles to "scoop up" pockets of black populations, which violates the Equal Protection Clause of the Fourteenth Amendment.
• The State's use of race was not narrowly tailored to a compelling interest.
• The map's configuration is a result of racial sorting rather than legitimate districting principles.

• The Court held that SB8 is an unconstitutional racial gerrymander because no compelling interest justified the State's use of race.
• Strict scrutiny applies when race predominates in districting; the Court identifies only two compelling interests that can satisfy this standard: avoiding imminent prison safety risks and remediating specific, identified instances of past discrimination that violated the Constitution or a statute (*Students for Fair Admissions, Inc. v. President and Fellows of Harvard College*).
• Compliance with §2 of the Voting Rights Act can be a compelling interest, but only if the race-based conduct is actually required by a proper construction of §2.
• The Court interpreted §2 to mean that minority voters are entitled to no more and no less "opportunity" than that which results from the application of the State's combination of permissible, nonracial districting criteria.
• This interpretation ensures §2 is congruent with the Fifteenth Amendment, which bars only state action "motivated by discriminatory purpose" (*Reno v. Bossier Parish School Bd.*), and prevents Congress from changing the constitutional right (*City of Boerne v. Flores*).
• The Court updated the *Thornburg v. Gingles* framework, ruling that illustrative maps provided by plaintiffs cannot use race as a criterion and must meet all the State's legitimate objectives, including specified political goals.
• The updated *Gingles* test requires that analyses of racial-bloc voting control for party affiliation to "disentangle race from politics" (*Alexander v. South Carolina State Conference of the NAACP*).
• The "totality of circumstances" inquiry must focus on present-day intentional discrimination, giving significantly less weight to historical data or the "effects of societal discrimination" (*Shaw v. Hunt*).
• Applying this, the Court found §2 did not require the additional district because the *Robinson* plaintiffs failed to provide maps meeting the State's political goals and failed to control for party affiliation.