26JUL

Tennessee map survives its first test

3 min read

10:41UTC

A three-judge panel let Tennessee's redrawn congressional map stand on 23 July, accepting that splitting Memphis three ways was about party advantage rather than race.

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PoliticsDeveloping

Key takeaway

Admitting a partisan motive now defeats a claim that Section 2 would once have carried.

A three-judge federal panel refused on 23 July to block Tennessee's redrawn congressional map, finding that the redraw "was driven by politics, not race" ¹. Panels of this kind hear constitutional redistricting challenges and their refusals at the preliminary stage are slow to unpick. The lines will govern the 6 August primary and the November general election.

The plaintiffs are three Memphis voters, the Black Clergy Collaborative of Memphis, the Memphis A. Philip Randolph Institute and The Equity Alliance. Their complaint is that the map carved the state's only Black-majority district across three seats. Lucas Cameron-Vaughn, legal director of the American Civil Liberties Union (ACLU) of Tennessee, said lawmakers "deliberately divided Black neighborhoods across multiple districts, minimizing their voting strength" ². The vote-dilution case continues to trial, so any remedy arrives after the seats have been filled.

Two prior rulings built the defence that worked here. The Supreme Court narrowed Voting Rights Act (VRA) Section 2 protection in Louisiana v. Callais, striking Louisiana’s second majority-Black district as unconstitutional on 29 April , and Governor Bill Lee signed the new Tennessee lines on 7 May, a week and a day later . Rucho v. Common Cause, decided in 2019, had already put partisan gerrymandering beyond the reach of federal courts while leaving racial gerrymandering actionable.

Read together, the two doctrines reward candour about party motive. A legislature that says on the record it was chasing Republican seats stands in better shape than one that says nothing at all, because the admission answers the only claim left. Plaintiffs must now prove racial intent rather than racial effect, and legislatures redrawing elsewhere after Callais have their first district-court data point saying the shield holds.

Deep Analysis

In plain English

Tennessee redrew its congressional map so that Memphis, a majority-Black city, no longer has a district where Black voters can elect their own preferred representative. Federal courts will strike down a map if it was drawn mainly to hurt voters because of their race, but the Supreme Court has ruled that courts cannot second-guess a map drawn mainly to hurt voters because of their political party, even when the two overlap heavily. Tennessee's lawmakers said this was about party, so the map stands for the August primary while the underlying racial-discrimination case continues at trial.

Deep Analysis

Root Causes

Tennessee's map survives because two separate doctrines closed off both routes a challenger could otherwise take. Rucho forecloses the partisan-gerrymandering claim outright, regardless of evidence.

Callais narrowed the Section 2 results test that had let plaintiffs prove vote dilution from a map's effect on Black voters without proving the legislature's intent . With the effects test gone, a challenger must prove the legislature's predominant purpose was race, not party, which is far harder when the legislature's own floor debate can be read either way.

What could happen next?

Precedent
Other legislatures that redrew maps after Callais now have a district-court data point suggesting the political-gerrymandering defence holds at the preliminary stage.
Consequence
The 6 August primary and the November general election both run on the new map regardless of the ongoing trial, so any eventual remedy would arrive after the seats are already filled.

Source Landscape

This story draws on neutral-leaning sources

Primary parallel: Rucho v. Common Cause held 5-4 on 27 June 2019 that federal courts cannot referee partisan gerrymandering claims, creating a safe harbour any state can claim by stating a party-advantage motive rather than a racial one; Louisiana v. Callais then removed the Voting Rights Act's Section 2 results test that had let plaintiffs route around that harbour by proving effect rather than intent (ID:3096).

Counter-parallel: Shaw v. Reno (1993) shows the opposite result under the same basic fact pattern: there, a map that used race as the predominant factor in drawing district lines was struck down even though the state defended it as a political, not racial, choice. The distinction the courts have drawn since is which factor the legislature says it weighed first, not which voters the map actually affects.

Consensus view: Michael Li, senior counsel for the Brennan Center's redistricting programme, has written that Rucho v. Common Cause (2019) made partisan gerrymandering claims non-justiciable in federal court, so any legislature that states a partisan motive on the record now has a ready defence against a map it might otherwise lose on racial grounds.

Counter-view: Trent England of Save Our States, which filed briefs supporting the Callais majority, argues that treating race and party as inseparable variables in the South, where voting is heavily correlated with both, is what forced courts into policing district lines as a proxy for policing political outcomes, and that Rucho and Callais together restore that line.

Key tension: Whether a legislature's admitted partisan purpose can ever be cleanly separated from its racial effect in a state where the two track each other this closely.

Sources:WSMV Nashville

Mentions:Tennessee →Memphis →Black Clergy Collaborative of Memphis →Memphis A. Philip Randolph Institute →The Equity Alliance →ACLU →Bill Lee →Supreme Court of the United States →Voting Rights Act →Common Cause →Louisiana →Louisiana v. Callais →

First Reported In

Update #14 · 0-for-17 in court, and the map that held

WSMV Nashville· 26 Jul 2026

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Causes and effects

Caused by

Callais guts VRA Section 2 mandate

Callais's April removal of the VRA Section 2 duty is the legal basis Tennessee's map relied on to survive this challenge.

Occurred 29 Apr 2026

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Tennessee signs map carving Memphis three ways

Tennessee's legislature carved Memphis across three districts months after Callais, producing the map this ruling upheld.

Occurred 7 May 2026

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This Event

Tennessee map survives its first test

The map governs the 6 August primary and the November general election whatever the vote-dilution trial eventually decides.

Different Perspectives

Senate Budget Committee under Ron Johnson

Johnson, reported to succeed the late Lindsey Graham as Budget chair on 22 July, has a record of opposing reconciliation packages on deficit grounds, a different proposition than his predecessor for carrying the $10bn voter-ID grant through the Senate on 51 votes after the House passed its version 216-214.

NRCC and Republican committee strategists

The NRCC's $92.7m cash on hand outweighs the DCCC's $79.0m by $13.7m even after Democrats out-raised them $37.4m to $35.4m in the second quarter, official FEC filings from 20 July confirmed. Strategists are banking on the reserve gap, not this quarter's receipts, to carry House races.

Memphis civil-rights plaintiffs

The Black Clergy Collaborative and allied Memphis plaintiffs argued Tennessee's redraw split the state's only Black-majority district to dilute their vote, and lost on 23 July when the panel found the map "driven by politics, not race". The ruling leaves it governing the 6 August primary while their underlying trial continues.

Department of Justice

DOJ filed notice of appeal on its Connecticut dismissal the same day, 23 July, a Kentucky court threw out an identical suit, its seventeenth loss without ever pleading which statute authorises the voter-file demand. It continues pressing 13 live cases on an appellate strategy that has produced one ruling, the 6th Circuit's Benson loss.

Overseas and military voters

1,051 UOCAVA voters had requested ballots for the original 9 June primary before Graham's death on 11 July moved the calendar entirely. Dhillon's 19-20 July agreement sets a fresh 1 August mailing date for the 11 August primary, a fix that arrived after the vacancy it addresses rather than before it.

South Carolina State Election Commission

Commission director Conway Belangia declared the June-primary crossover review "completed" on 16 July, barring anyone who voted in the June Democratic primary from the 11 August Republican special primary, citing only "the requirements of South Carolina election law" without naming the statute. Both parties accepted the ruling rather than challenge it.