Allen v. Milligan

Docket Number: 25A1314
Citation: 608/2
Term: October Term 2025
Decided: June 2, 2026
Lower Court: United States District Court for the Northern District of Alabama
Author: PC
Dissenting: Sonia Sotomayor, Elena Kagan, Ketanji Brown Jackson

AI-Generated Summary

Case Information:

Case Name: Wes Allen, Alabama Secretary of State, et al. v. Evan Milligan, et al.; Wes Allen, Alabama Secretary of State, et al. v. Bobby Singleton, et al.; Wes Allen, Alabama Secretary of State, et al. v. Marcus Caster, et al.
Docket Number: Nos. 25A1314, 25A1315, 25A1316
Dates: June 2, 2026 (decision on applications for stay)
Lower Court: United States District Court for the Northern District of Alabama

Facts of the Case:

Following the Supreme Court’s decision in Louisiana v. Callais, 608 U. S. ___ (2026), which updated the Gingles preconditions for §2 vote-dilution claims under the Voting Rights Act of 1965, the Court had previously vacated District Court injunctions against Alabama’s 2023 congressional map.
The District Court then issued a new preliminary injunction on May 26, 2026, again barring the 2023 map on grounds of both §2 violation and intentional racial discrimination under the Fourteenth Amendment, ordering use of a remedial map.
Alabama state officials applied for a stay of this new injunction.

Legal Issues Presented:

Whether the District Court’s May 26, 2026, injunction should be stayed pending appeal or certiorari.
The case involves interpretation of §2 of the Voting Rights Act (updated by Callais) and the Fourteenth Amendment’s prohibition on intentional racial discrimination in redistricting.
The State argues the District Court failed to apply Callais standards, the presumption of legislative good faith, and the Purcell principle against altering election rules close to an election; plaintiffs contend the injunction properly remedies both discriminatory effect and purpose.

The Court's Decision (Main Opinion):

Author & Type: Per Curiam opinion.
Holding: The State is entitled to a stay; it is likely to succeed on the merits of both its §2 and Fourteenth Amendment claims, has shown irreparable harm, and the equities favor interim relief.
Legal Reasoning: Under Callais, plaintiffs’ alternative maps must perform “just as well” as the State’s map on all legitimate, constitutionally permissible districting criteria (including political goals and communities of interest) and must control for party affiliation when proving racial bloc voting. The District Court did not apply these standards, disregarded the presumption of legislative good faith by treating legal disagreement as animus, and violated the Purcell principle by intervening close to the 2026 elections.
Disposition: Applications for stay granted; the District Court’s May 26, 2026, order is stayed pending appeal or certiorari proceedings.

Concurring Opinion(s) (if any):

Dissenting Opinion(s) (if any):

Justice Sotomayor, joined by Justices Kagan and Jackson.
The dissent argues the District Court correctly found both discriminatory effect (previously affirmed in Allen v. Milligan) and purpose; Alabama’s 2023 map was adopted in defiance of a prior court order and made a second opportunity district mathematically impossible through new, pretextual criteria. The stay rewards gamesmanship, violates Purcell by creating administrative chaos for hundreds of thousands of voters, and undermines the rule of law.

Potential Significance:

Reinforces the updated Callais requirements for §2 liability, the presumption of legislative good faith, and the Purcell principle against late-stage judicial changes to election maps.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: Congressional Redistricting, Voting Rights Act, Racial Vote Dilution