Nairne v. Landry is a lawsuit that was filed in March 2022 challenging Louisiana’s House and Senate legislative maps that severely dilute the voting strength of Black voters. The lawsuit argues that Louisiana legislative maps violate Section 2 of the Voting Rights Act of 1965 (VRA).
The Legal Defense Fund, American Civil Liberties Union (ACLU), ACLU of Louisiana, Harvard Law School Election Law Clinic, Cozen O’Connor, and Louisiana attorneys Ron Wilson and John Adcock brought the Section 2 challenge on behalf of individual Black voters across Louisiana, the Louisiana State Conference of the NAACP, and Black Voters Matter Capacity Building Institute.
Both the state House and Senate maps pack Black voters into a small number of majority-Black districts and crack other Black communities across other districts to prevent them from receiving effective representation. As a result, Black voters in Louisiana cannot participate equally in the political process or elect candidates of their choice outside of a few majority-Black districts.
The lawsuit argued that the maps dilute the voting power of Black Louisianians in violation of Section 2 of the VRA by failing to add additional majority-Black districts where Black voters would have an equal opportunity to elect candidates of their choice to their legislature, while patterns of stark racially polarized voting persist across the state.
Plaintiffs in Nairne represented that it is possible to create multiple additional districts that provide Black voters the opportunity to elect their candidates of choice to the Louisiana State Senate and House redistricting plans.
The law and the facts call for fair maps. In Allen v. Milligan (2023), the U.S. Supreme Court upheld decades of precedent under Section 2 of the VRA and recognized that attacks on the voting rights of Black voters continue today. That law applied here and confirmed that the need for new and fair state legislative maps can no longer be denied.
This case shows that Black voters have a right under federal law to greater representation at the Louisiana State Capitol. A map that reflects three additional majority-Black Senate districts and six additional majority-Black House districts would provide Black voters with greater opportunity to not only shape the outcome of elections in their communities but the future of key policies for this state.
Black Louisianians have faced generations of discrimination in political representation. Fair representation can lead to real change for Black communities and help improve disparities in education, healthcare access, environmental safety, infrastructure, and more. This litigation can finally chart a more hopeful direction for the State of Louisiana and our nation’s promise of democracy.
In March 2022, the Louisiana Legislature passed maps for their own districts in the State Senate and House of Representatives that severely diluted the voting strength of Black voters. That Nairne plaintiffs quickly filed suit.
In August 2022, the litigation came to a standstill when the Louisiana federal court issued a stay of all proceedings in the case while awaiting the Supreme Court’s decision in Allen v. Milligan, a case regarding Section 2 of the VRA as applied to congressional districts in Alabama. In its June 2023 ruling in Milligan, the Supreme Court reaffirmed the legal framework that guides courts in evaluating challenges to redistricting plans under Section 2. Following that decision, the District Court lifted the stay in Nairne.
Trial in Nairne began on November 27, 2023 at the federal courthouse in Baton Rouge and concluded on Tuesday, December 2, 2023. On February 8, 2024 the District Court ruled that both the State House and Senate maps violated Section 2 of the VRA and prohibited future elections to be held on the maps, finding evidence of vote dilution in all the challenged districts. On February 19, 2024, Defendants filed a notice of appeal.
Though the appeal remains pending, with arguments set for January 7, 2025, Plaintiffs argue that special elections should be held prior to the next state legislative elections in 2027.
This piece explores how three states with discriminatory maps have shirked their responsibilities to their constituents, paving the way for the passage of oppressive legislation.
Understanding the role of race in the redistricting process as a means of ensuring equitable representation and political power is critical.
LDF has closely monitored the redistricting process in key states to ensure that maps are drawn fairly and do not disenfranchise Black voters. This guide provides an overview of LDF’s work during the 2021 redistricting cycle and litigation filed.
We’ve compiled answers to frequently asked questions about the seminal U.S. Supreme Court case Allen v. Milligan and its impact on voting rights and redistricting.
