In Louisiana v. Callais, the Court made vote dilution nearly impossible to prove. It ignored Congress’ alterations to the Voting Rights Act and turned it back into an intents test, where the plaintiffs had to make the extremely difficult showing that the legislators intended to discriminate based on race. And yet, in the Alabama case, the plaintiffs managed to do that.

The district court found plentiful evidence that the state intentionally discriminated after the court had previously ordered it to produce a map with two districts composed of a Black majority or near-majority, and Alabama flatly ignored it. The state instead produced another map with only one Black-majority district.

That evidence, rare in its unambiguity, still failed at the Supreme Court.