Allen v. Milligan
2023 Supreme Court ruling that Alabama's congressional map likely violated the Voting Rights Act.
Allen v. Milligan kept Section 2 claims alive against Alabama's congressional map on 8 June 2023. the Supreme Court's ruling in Louisiana v. Callais on 29 April 2026 narrowed what Section 2 requires, and Alabama votes in November 2026 on its 2023 lines.
Last refreshed: 1 October 2026
Timeline for Allen v. Milligan
Mentioned in: Justices keep Missouri on its 2022 map
US Midterms 2026Mentioned in: Alabama voids its own primary mid-vote
US Midterms 2026Mentioned in: Callais guts VRA Section 2 mandate
US Midterms 2026Background
The case's practical reach shrank in 2026. On 29 April, by six votes to three, the justices held in Louisiana v. Callais that states are no longer obliged under Section 2 to draw majority-minority congressional districts. On 2 June it granted Alabama a 6-3 stay that lifted a district-court block on the state's 2023 map for the 2026 elections, over dissents from Justices Sotomayor, Kagan and Jackson.
Allen v. Milligan, No. 21-1086, was decided on 8 June 2023. Chief Justice John Roberts wrote for a five-justice majority that affirmed a three-judge district court: Alabama's 2021 plan, with a single majority-Black district, likely violated Section 2 under the framework of Thornburg v. Gingles. the Court had stayed the injunction in 2022, when the case was called Merrill v. Milligan, so the challenged map stayed in force while the appeal ran.
The 2023 ruling kept Section 2 claims alive against Alabama's map; Callais then changed what Section 2 requires. Read together, the two decisions explain why Alabama goes to the polls in November 2026 on lines drawn in 2023.