Supreme Court’s LULAC Ruling Makes Federal Challenges to Gerrymandering Far Harder

Supreme Court Restores Texas Map in Abbott v. LULAC

The Supreme Court on Thursday evening reinstated a contested Texas congressional map that a lower federal court had struck down, a move expected to add roughly five Republican seats to the U.S. House. The order in Abbott v. League of United Latin American Citizens (LULAC) drew a sharply partisan response: the Court’s three Democratic justices dissented, while the conservative majority provided a brief order reinstating the map.

What the Ruling Says

The Court’s short order did not dispute many of the lower court’s factual findings but criticized the trial court for failing to apply a robust presumption of legislative good faith. The majority faulted the lower court for construing ambiguous evidence against the state and emphasized procedural and evidentiary requirements that plaintiffs must meet to sustain a racial-gerrymandering claim.

“The District Court failed to honor the presumption of legislative good faith by construing ambiguous direct and circumstantial evidence against the legislature.” — LULAC majority

Why This Matters

The decision raises several new hurdles for plaintiffs who challenge maps as racial gerrymanders. Key developments include:

• Presumption of Legislative Good Faith: The Court reinforced that, absent overwhelming proof, courts should not readily infer racial motivations from ambiguous evidence.
• Alternative-Map Requirement: Plaintiffs are criticized if they fail to submit a “viable alternative map” that preserves the state’s asserted partisan goals while reducing race-based effects — a requirement the Court treats as nearly dispositive.
• High Burden Where Motives Are Mixed: Because partisan and racial motives often overlap (for example, where Black voters disproportionately support one party), defendants can point to partisan aims to counter claims of racial predominance.

Case Background

Before Texas adopted the disputed plan, the U.S. Department of Justice under the Trump administration sent a letter urging Texas to redraw certain districts to change racial composition — a step that critics say pressured the state to alter district lines. The lower court concluded there was considerable evidence that Texas reconfigured its districts in response to that DOJ letter and declared the plan unconstitutional on November 18, 2025.

The Supreme Court’s LULAC order did not explicitly reverse the lower court’s factual findings but held that the trial court applied the wrong evaluative posture by not giving the legislature the presumption of good faith and by relying on ambiguous evidence against the state.

Implications and Concerns

Legal experts warn that LULAC, taken with prior decisions such as Rucho v. Common Cause (2019), Abbott v. Perez (2018), and Alexander v. South Carolina NAACP (2024), substantially narrows federal remedies for both partisan and racial gerrymanders. The ruling is likely to have several effects:

• Chilling Effect on Litigation: Civil-rights groups and private plaintiffs may be less likely to bring suits if the evidentiary and procedural hurdles make success unlikely.
• Fewer Judicial Remedies: Courts will be more deferential to legislatures unless plaintiffs can show overwhelming direct evidence of racial predominance or supply an equally partisan alternative map with fewer race-based effects.
• Political Consequences: Reinstating the Texas map is expected to shift roughly five seats toward Republicans in the next applicable House elections, altering electoral balance.

What Comes Next

Lower courts, litigants, and state legislatures will now operate with the heightened standards LULAC articulated. Plaintiffs seeking to challenge maps on racial grounds will face a steeper evidentiary climb and a practical requirement to propose alternative plans that satisfy partisan objectives — a task that can be technically difficult and politically fraught.

Viewed cumulatively with earlier precedents, LULAC represents a significant narrowing of federal oversight of redistricting and signals a more deferential posture by the Supreme Court toward state mapmakers.