Louisiana Effort to Redistrict Black Voters Denied on Appeal (1)

Louisiana lost its bid to reverse a lower court ruling that its redrawn state legislative district maps deprives its Black citizens of the opportunity to form effective voting blocks in violation of the federal Voting Rights Act.

The ruling is a setback for Louisiana Republicans who sought to redraw the state’s legislative district voting maps in their favor.

Louisiana and its secretary of state, Nancy Landry, failed to persuade the US Court of Appeals for the Fifth Circuit that the lower court made a series of compounding errors leading to a flawed ruling requiring the state to redo its district plans.

The Fifth Circuit said the the district court’s analysis was thorough and reasoned, and the plaintiffs’ claimed section 2 violation of the VRA occurred based on the totality of the circumstances.

The decision shows the VRA “is still a vital safeguard against racial discrimination in our democracy,” ACLU Voting Rights Project staff attorney Megan Keenan said via email. “The court recognized the reality that many Black voters in Louisiana have been denied full and fair representation. This ruling brings us one step closer to the inclusive political process our clients and communities across the state deserve.”

The Louisiana secretary of state’s office didn’t immediately respond to a request for comment.

‘Crack or Pack’

A group of Black voters and organizations that work to expand Black voter engagement in Louisiana sued Landry in 2022, alleging the state legislature’s then-newly redrawn legislative districts diluted the power of Black voters in the districts in which they reside, in violation of Section 2 of the act.

A Baton Rouge, La., federal judge found the maps “crack or pack large and geographically compact minority populations” in the challenged districts and issued a permanent injunction barring the maps and ordering state lawmakers to address the issues with the challenge districts.

On appeal Landry argued the district court failed to conduct an “intensely local appraisal,” and imposed a “rushed” schedule that didn’t allow for the parties to collect and analyze data on the maps and alleged dilution from the November 2023 elections.

But the appellate panel backed the lower court decision, stating that the district court didn’t err when it weighed various factors to determine whether a section 2 violation occurred based on the totality of circumstances. This includes the extent to which a state has a history of official discrimination, polarization based on race, and whether a state has used voting practices to enhance the opportunity for discrimination against a minority group.

The record is replete with evidence, for example, of Louisiana closing polling places and restricting access to early voting, the three-judge panel said.

The district court also properly considered evidence showing that Black Louisianans experience social and economic disparities that negatively affect their ability to register to vote and participate in elections, the appeals court said.

Judges Catharina Haynes, James L. Dennis, and Irma Carrillo Ramirez joined in the per curiam opinion. Haynes concurred in the judgment, the opinion said.

The American Civil Liberties Union Foundation, Cozen O’Connor PC, the NAACP Legal Defense and Educational Fund Inc., and others represent the plaintiffs. Nelson Mullins Riley & Scarborough LLP and Shows, Cali & Walsh LLP represent Landry. Baker & Hostetler LLP represents the state legislative leaders. The Louisiana Office of the Attorney General and Holtzman Vogel Baran Torchinsky & Josefiak PLLC represent Louisiana.

The case is Nairne v. Landry, 5th Cir., No. 24-30115, 8/14/25.