Skip to content
Welcome, thoughtbot's Giant Robots listeners!Start here
US Midterms 2026
15SEP

Tennessee map survives its first test

3 min read
14:21UTC

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.

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.

First Reported In

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

WSMV Nashville· 26 Jul 2026
Read original →
Different Perspectives
Department of Justice (DOJ)
Department of Justice (DOJ)
DOJ appealed to the 9th Circuit after Judge David O. Carter did not rule by a noon deadline on 22 October that DOJ itself had set, seeking to have California set aside mail ballots from more than 20,000 listed voters. Its case is that ineligible votes cancel lawful ones; the panel dismissed the appeal 2-1 on 26 October.
Lower Costs Now
Lower Costs Now
Lower Costs Now reported $7.37m in Kansas on 24 and 25 October, part of $65.65m in Senate races since its first independent expenditure on 1 October, including $17.21m for Josh Turek in Iowa. Its FEC filings show $50.18m raised by 14 October.
MAGA Inc
MAGA Inc
MAGA Inc, the super PAC aligned with Donald Trump, filed $7.20m against James Talarico on 22 October, taking its Texas spending to $37.65m. Of that, $30.12m is against Talarico and $7.53m is for Ken Paxton, the Republican nominee.
Senate Majority PAC (SMP)
Senate Majority PAC (SMP)
SMP's pre-general report shows it spent $108.70m from 1 to 14 October, including $65.0m to WinSenate and $10.0m to Texas Forever, and ended with $32.72m. Texas Forever has reported $19.40m against Ken Paxton since 1 October.
Senate Leadership Fund (SLF)
Senate Leadership Fund (SLF)
SLF's pre-general report shows $88.42m in cash on 14 October and $18.98m raised in the fortnight, none of it from Elon Musk. It has since reported $12.07m against Sherrod Brown in Ohio, and its $2.7m to Plains PAC preceded that committee's first Kansas buy on 25 October.
National Republican Senatorial Committee (NRSC)
National Republican Senatorial Committee (NRSC)
The NRSC's pre-general report shows nothing spent with Ashley Hinson in Iowa, or with its nominees in six other states, from 1 to 14 October, after $5.54m with Hinson in September. It took no new loan and ended the fortnight with $25.20m in cash and $20m of debt.

Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Editorial standards.