29MAY

Tennessee signs map carving Memphis three ways

3 min read

08:48UTC

Governor Bill Lee signed Tennessee's new congressional map on Thursday 7 May, eliminating Steve Cohen's majority-Black 9th district and leaving all nine seats Republican-leaning.

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Key takeaway

Tennessee delivers up to two Republican House seats by January 2027 without any 2026 vote being cast in the state.

Governor Bill Lee signed Tennessee's new congressional map on Thursday 7 May, twelve days before the Alabama trigger. All nine districts are now Republican-leaning. The map carves Memphis and Shelby County across the 5th, 8th and 9th districts, eliminating the majority-Black 9th held by Representative Steve Cohen ¹. The special session that produced the map convened on Tuesday 5 May.

The redraw delivers up to two additional House seats by January 2027 without any vote being cast in Tennessee. Louisiana v. Callais removed the Voting Rights Act Section 2 majority-minority mandate that had protected Cohen's district, the same legal lift that cleared Alabama's map seven days later. Tennessee was one of the four states that opened special sessions in the days after the 29 April ruling, and Lee's signing is the cleanest of those four resolutions to land on the calendar.

The template is Ron DeSantis's Florida 24R-4D map, signed three days earlier on 4 May and immediately challenged. Tennessee and Florida together have moved roughly nine seats from Democratic-held or competitive to Republican-leaning before any 2026 ballot is cast in either state. Brookings Institution analyst Vanessa Williamson called Memphis the cleanest example of a single Black-majority city dispersed across three districts to dilute Section 2 protection; the counter-view, advanced by State Senator Jack Johnson in the Tennessean, is that the city's geography makes a coherent 9th district impractical without crossing Shelby County boundaries the new map respects.

Unlike Florida, Tennessee draws no obvious state-law challenge. The Tennessee constitution carries no Fair Districts equivalent, and the federal Section 2 path closed with Callais. That leaves the 9th's elimination largely uncontested in court, in contrast to the Florida challenge under Judge Hawkes that may yet land before 8 June qualifying.

Deep Analysis

In plain English

Memphis is a majority-Black city in Tennessee. For decades, there was a congressional district drawn around Memphis that gave Black voters enough numbers to elect a representative of their choice. That representative was Steve Cohen, who has held the seat since 2007. In April 2026, the Supreme Court struck down the rule that required that kind of district to exist. Eight days later, Tennessee's governor called the legislature into special session. Within two days the legislature redrew the map. Instead of one Memphis district, the new map cuts the city into three pieces, each now part of a larger district dominated by rural Republican voters. Lee's signed map eliminated Cohen's 9th District by carving Memphis across three Republican-leaning districts. Up to two more Republican seats will appear in Congress from Tennessee by January 2027, without any election having been held under the new lines.

Deep Analysis

Root Causes

The Tennessee map's structural root is the Gingles framework's removal.

Thorнburg v. Gingles (1986) required states with sufficiently large and compact minority communities to preserve the possibility of a majority-minority district. Memphis, with a majority-Black city population, met the Gingles compactness and size tests.

That requirement forced Tennessee's pre-Callais mapmakers to draw the 9th district around Memphis rather than across it. Callais removed that floor on 29 April. The special session on 5 May and Lee's signature on 7 May moved on a calendar of eight days from judicial signal to signed law.

A secondary structural factor is Tennessee's absence of any state constitutional redistricting standard equivalent to Florida's Fair Districts Amendment or California's commission structure. The Tennessee constitution contains no independent partisan-intent prohibition.

With Section 2 gone and no state-law substitute, the legislature's only constraint was the federal Equal Protection Clause's racial-intent doctrine, which requires plaintiffs to prove discriminatory purpose rather than effect. Effect-based claims under Section 2 were precisely what Callais removed.

What could happen next?

Consequence
Tennessee delivers up to two Republican House seats by January 2027 with no litigation path available, making it the cleanest Callais harvest among the four states that called post-ruling special sessions.
Immediate · 0.87
Precedent
The eight-day sequence from SCOTUS ruling to signed map sets the operational speed standard for post-Callais redistricting: contingent maps prepared in advance, special sessions called within 24 hours, gubernatorial signature within one week.
Medium term · 0.82
Risk
A racial-intent equal-protection challenge citing the speed and the explicit targeting of Cohen's seat could survive Callais as a distinct cause of action. No plaintiff has yet filed in Tennessee, unlike Florida where a challenge was filed within hours of DeSantis's signature.
Short term · 0.48

Source Landscape

This story draws on left-leaning sources from United States

United States

LeftRight

Primary parallel: Texas's 2003 mid-decade redistricting under Tom DeLay is the direct structural precedent for Lee's 7 May action. DeLay orchestrated a special session in 2003 to redraw the Texas congressional map mid-decade after Republicans won the state legislature, eliminating multiple Democratic incumbents and delivering six additional seats.

The Supreme Court upheld the map in League of United Latin American Citizens v. Perry (2006), ruling that mid-decade redistricting is constitutionally permissible. Tennessee follows the same playbook: a governor's call, a special session, a map drawn to maximise partisan advantage, with no state-law obstacle.

Counter-parallel: Georgia's 2021 redistricting eliminated Representative Lucy McBath's majority-Black district in the Atlanta suburbs by merging it with a Republican-leaning district. McBath ran in the adjacent district and won. The Georgia outcome suggests that Black incumbents losing their drawn-for-them districts are not automatically eliminated: Cohen could contest the 5th or 8th district, though the geography would make that substantially harder than McBath's Atlanta-adjacent move.

Consensus view: Brookings Institution analyst Vanessa Williamson identifies Memphis as the textbook application of cracking, the mapmaker's technique of splitting a geographically concentrated minority community across multiple districts so that it forms a minority in each.

Before Callais, the Gingles test from Thornburg v. Gingles (1986) required mapmakers to avoid cracking communities that were sufficiently large and geographically compact to form a majority district. Lee's 7 May map does precisely what Gingles prohibited, now lawfully.

Counter-view: State Senator Jack Johnson, quoted in the Tennessean, argues Memphis's geography makes a coherent majority-Black district impractical without crossing Shelby County boundaries the new map respects.

On the Johnson reading, the map's three-way split reflects topographic constraint rather than partisan design, and the Section 2 doctrine never fit Tennessee's urban geography. Cato Institute redistricting counsel argues this is the constitutionally neutral position the Court has now restored.

Key tension: Whether the absence of any state-constitution analogue to Florida's Fair Districts Amendment means Tennessee's map is legally unassailable, or whether a racial-intent equal-protection claim survives Callais as a distinct federal cause of action.

First Reported In

Update #6 · A primary nullified mid-vote

CNN· 19 May 2026

Read original →

Causes and effects

Caused by

Callais guts VRA Section 2 mandate

Callais removed the VRA majority-minority mandate, enabling Tennessee's all-Republican map that carves Memphis and eliminates Cohen's district.

Occurred 29 Apr 2026

Read story →

DeSantis signs Florida 24R-4D map into law

DeSantis's Florida 24R-4D map provided the template Tennessee followed in its post-Callais redraw.

Occurred 4 May 2026

Read story →

Four states queue maps after Callais ruling

Tennessee was one of the four states that called post-Callais sessions within 72 hours; the Lee signature is the direct outcome.

Occurred 30 Apr 2026

Read story →

This Event

Tennessee signs map carving Memphis three ways

Delivers up to two additional Republican House seats by January 2027 with no 2026 vote required.

Different Perspectives

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Democracy Docket / voting-rights litigators

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