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Eight Days: How Tennessee Dismantled Its Only Majority-Black Congressional District
On April 29, 2026, the U.S. Supreme Court issued its 6-3 decision in Louisiana v. Callais, ruling that race-conscious redistricting to comply with Section 2 of the Voting Rights Act constituted an unconstitutional racial gerrymander under the Fifteenth Amendment [1]. Eight days later, Tennessee Governor Bill Lee signed into law a new congressional map that eliminates the state's only majority-Black congressional district — making Tennessee the first state to act on the ruling [2].
The speed was extraordinary. The map went from nonexistent to signed law in a single week, a process that during the 2020 redistricting cycle typically took states months of hearings, public comment periods, and legislative debate.
What the Map Does
Tennessee's 9th Congressional District, centered on Memphis, has been the state's sole majority-Black district for over three decades. Approximately 60% of its voting-age population is Black [3]. Under the new map, Memphis and Shelby County — which currently form a unified district represented by Democratic Rep. Steve Cohen — are split into three separate districts [4].
The result: each of those three new districts would have a Black voting-age population of roughly 29-30%, an almost precise trisection of the city's Black electorate [3]. State Rep. Torrey Harris called it an "almost exact division of Memphis' Black population" [3].
Nashville, the state's other major Democratic stronghold, which was already split among three districts after the 2021 redistricting, is now divided among five districts under the new map [5]. The combined effect would make all nine of Tennessee's congressional seats lean Republican, eliminating the state's last remaining Democratic-held seat and leaving Tennessee with an entirely Republican congressional delegation for the first time in its history [6].
The Legislative Sprint
The timeline from Supreme Court ruling to signed law compressed what is normally a months-long process into eight days:
- April 29: Supreme Court rules in Louisiana v. Callais [1]
- May 1: Governor Lee calls a special legislative session to begin May 5 [7]
- May 5: Special session convenes; Republicans limit public testimony [8]
- May 6: Map introduced publicly for the first time [9]
- May 7: Both chambers vote; Lee signs the map into law the same day [2]
The map was publicly available for roughly 24 hours before the final vote. House Speaker Cameron Sexton argued the map was straightforward enough that it "doesn't seem too complicated" to review in that window [3]. During the 2020 redistricting cycle, most states held weeks or months of public hearings before finalizing congressional maps. Tennessee's process included no formal public hearings on the specific map that was adopted [8].
To pass the map at all, Republicans first had to repeal Tennessee Code Section 2-16-102, a state law that had prohibited mid-decade congressional redistricting for over fifty years [10]. That repeal was itself passed during the special session, hours before the map vote.
Chaos on the Floor
The final day of the three-day special session was marked by protests, walkouts, and arrests. Hundreds of demonstrators packed Capitol hallways [11]. House Speaker Sexton ordered state troopers to remove the public from galleries after brief clapping; three protesters were arrested, including KeShaun Pearson, brother of state Rep. Justin Pearson (D-Memphis) [11].
Rep. Justin Jones (D-Nashville) handed a printed Confederate flag to House Majority Leader William Lamberth, accusing Republicans of acting as a "white sheet caucus." Lamberth crumpled the printout and threw it on another lawmaker's desk [11]. Jones later burned another printout in the hallway. Sen. Charlane Oliver (D-Nashville) climbed onto her desk and unfurled a banner reading "No Jim Crow 2.0 Stop the TN Steal," which security physically removed from her hands [11].
Both Democratic caucuses walked out. Lawmakers dressed in white to honor the suffrage movement, shouted objections, and sang from their desks. After adjournment, Democrats wept, raised fists, and embraced as protesters cheered [11].
The Legal Landscape After Callais
The Tennessee map exists in a legal environment that has shifted dramatically from just three years ago. In 2023, the Supreme Court ruled 5-4 in Allen v. Milligan that Alabama's congressional map likely violated Section 2 of the Voting Rights Act by failing to include a second majority-Black district [12]. That ruling, which reaffirmed the Thornburg v. Gingles framework for vote dilution claims, forced Alabama to create an additional majority-minority district and led to similar outcomes in Louisiana and Georgia.
Louisiana v. Callais reversed that trajectory. Writing for the 6-3 majority, Justice Alito held that Louisiana's second majority-Black district — the very map created to comply with Section 2 litigation — was itself an unconstitutional racial gerrymander [1]. The ruling concluded that race-conscious compliance with Section 2 violates the Fifteenth Amendment, a standard that voting rights groups say effectively hollows out Section 2's enforcement mechanism [13]. The statute remains on the books, but challengers must now prove that a map was drawn with intentional discriminatory purpose — a far higher bar than the effects-based test that Gingles established [14].
This shift explains Tennessee's speed: the legal shield that would have blocked the map a year ago had been removed.
The Republican Case
Republican lawmakers made their arguments in explicitly partisan terms. State Senator John Stevens stated: "These maps were drawn to maximize our partisan advantage" [4]. Speaker Sexton argued that the Supreme Court had "opined that redistricting...should be color-blind" and that states can now redistrict based on partisan considerations [4].
House Majority Leader Lamberth offered a policy rationale, arguing that combining urban and rural populations within the same districts would produce "more diverse representation" by forcing members of Congress to answer to both constituencies [3]. "Is it better in a state like Tennessee, where we have a rich agrarian history, for our urban areas and our rural areas to be within the same district?" he asked [3]. The argument drew laughter from critics in the gallery.
Some conservative legal scholars have long argued that majority-minority districts can themselves constitute racial gerrymanders under Shaw v. Reno (1993), which held that redistricting based predominantly on race is subject to strict scrutiny under the Equal Protection Clause [15]. The Callais majority drew on this reasoning, treating the creation of majority-Black districts as racial sorting that the Constitution prohibits. Whether the prior Tennessee 9th District was vulnerable to a Shaw challenge is a question that was never litigated, but the district's geographic compactness — it encompassed Memphis and surrounding Shelby County in a contiguous urban area — would have made such a challenge difficult, as Shaw claims have historically targeted irregularly shaped districts drawn to connect disparate minority populations.
National Coordination
Tennessee's action is part of a broader, coordinated Republican redistricting effort across Southern states. President Trump initiated the push by urging the Texas legislature to redraw its congressional maps in mid-2025 [14]. After the Callais ruling, Trump and Tennessee U.S. Senator Marsha Blackburn directly pressured state lawmakers to redraw the map in time for the 2026 midterms [6].
Multiple states moved simultaneously. Louisiana paused its House primaries pending redistricting. Alabama sought to redraw its congressional map. Mississippi's legislature was identified as likely next in line [16]. Both Republican- and Democratic-controlled legislatures in states including Missouri, California, Ohio, North Carolina, and Virginia also pursued redraws, though the Southern efforts targeting majority-minority districts followed a distinct pattern [14].
The specific donors, PACs, and outside legal groups advising the Tennessee redistricting effort have not been publicly identified in reporting to date. The Tennessee Registry of Election Finance does not yet reflect expenditures related to the special session. This remains an area where the full picture of coordination is incomplete.
Electoral Consequences
Under the current map, Tennessee sends eight Republicans and one Democrat to Congress. Under the new map, all nine seats would lean Republican [6]. The old 9th District was the state's only competitive or Democratic-leaning seat; its elimination would end Tennessee's Black representation in Congress for the first time since 1972.
Rep. Steve Cohen, who has represented the Memphis-based district since 2007 and is himself white, announced he would sue to block the map [4]. The Congressional Black Caucus condemned the redistricting as "tantamount to theft — the theft of fair representation" [4].
The national implications are significant but bounded. Republicans' redistricting gains across multiple states could net the party several additional House seats. However, election forecasters have noted that most of the 435 House districts currently lean Democratic heading into an unfavorable midterm environment for the party holding the White House, limiting how much redistricting alone can shift the House majority [14].
Legal Challenges and the Path Forward
The NAACP filed an emergency lawsuit on May 7, the same day Governor Lee signed the map, in Davidson County Chancery Court [10]. NAACP Tennessee President Gloria Sweet-Love filed the petition against Lee and the General Assembly [17].
The lawsuit takes a deliberate strategic approach: rather than relying on the now-weakened federal Voting Rights Act, it challenges the map primarily under Tennessee state law and the state constitution [10]. The central arguments are:
- Lack of authority: Tennessee Code Section 2-16-102 prohibited mid-decade redistricting for over fifty years. The NAACP argues the repeal was itself unlawful [10].
- Special session limits: Under Tennessee's constitution, lawmakers in special sessions may only consider issues specifically identified by the governor's proclamation. The NAACP argues the proclamation did not authorize repealing the redistricting prohibition [10].
- Residency requirements: Republicans suspended a one-year residency requirement for congressional candidates, which the NAACP argues was done solely to allow candidates with no connection to newly drawn districts to run [10].
- Voter notification: The legislature eliminated mail notification requirements when redistricting changes voters' polling places or precincts [10].
The lawsuit seeks to void the repeal of the redistricting prohibition, block the new map, and prevent elections under the newly drawn districts [10].
The timeline is tight. Tennessee's primary election is scheduled for August 6, 2026 [5]. For the courts to intervene, they would need to issue injunctive relief well before that date to allow election administration to proceed under either the old or new maps. The NAACP's decision to file in state court rather than federal court reflects both the weakened state of federal voting rights protections and a calculation that Tennessee's own constitutional provisions offer a viable path to blocking the map.
Beyond the NAACP suit, civil rights leaders and faith communities have mobilized. Martin Luther King III wrote to Tennessee legislative leaders warning that the redistricting effort would "dismantle hard-won protections rooted in the Civil Rights Movement," urging them: "Do not dismantle the only Congressional district that provides Black voters in Memphis a fair opportunity to have a voice in our democracy" [18]. Rev. Earle Fisher of Abyssinian Missionary Baptist Church and founder of Up the Vote 901 framed the stakes bluntly: "It's about whether the voices of Black people in this state will be heard or hidden" [18].
Historical Context
Tennessee has maintained one majority-minority congressional district since the early 1990s redistricting that followed the 1990 Census. The 9th District, centered on Memphis, has been that district through each subsequent cycle — 2000, 2010, and 2020 [19]. Memphis itself is approximately 64% Black, and Shelby County's Black population has remained stable or grown slightly over the past three decades.
During the 2021 redistricting, Tennessee Republicans redrew maps to split Nashville among three districts, eliminating the Democratic lean of what was then the 5th District [5]. That move presaged the current action against Memphis. The pattern — fragmenting urban, diverse populations into multiple rural-dominated districts — has been a recurring feature of Republican redistricting in Southern states.
Whether the Tennessee map survives legal challenge will depend significantly on the state courts' interpretation of Tennessee's own constitutional constraints. The federal path has narrowed considerably after Callais. But the state-law arguments — particularly the questions about the special session's scope and the repeal of the mid-decade redistricting ban — present distinct legal questions that the Supreme Court's Voting Rights Act jurisprudence does not directly control. The coming weeks before the August primary will determine whether those arguments are enough to stop a map that was eight days in the making.
Sources (19)
- [1]Supreme Court guts Voting Rights Act, greenlights GOP gerrymandersdemocracydocket.com
The 6-3 U.S. Supreme Court decision in Louisiana v. Callais eviscerated Section 2 of the Voting Rights Act, ruling that race-conscious compliance is unconstitutional.
- [2]Tennessee lawmakers approve new congressional map that dissolves majority Black districtcbsnews.com
Tennessee's Republican-controlled legislature approved a new congressional map splitting Memphis into three districts. Governor Lee signed it the same day.
- [3]Critics say redistricting plan disenfranchises Black votersnashvillebanner.com
The proposed new Memphis districts would each be between 29-30% Black, compared to the current 9th District's 60%+ Black voting-age population.
- [4]Tennessee Republicans pass map dividing up state's lone majority-Black districtnbcnews.com
Republican state Senator John Stevens stated maps were drawn to maximize partisan advantage. The Congressional Black Caucus condemned the action as 'tantamount to theft.'
- [5]Tennessee Republicans pass a map to break up the state's lone Democratic House seatnpr.org
Lee signed a bill repealing a decades-old state law against mid-decade redistricting hours before the map vote. Primary elections are scheduled for August 6, 2026.
- [6]Tennessee approves GOP-friendly redistricting proposal, drawing out lone Democratthehill.com
The redrawn district lines put Republicans in position to gain a seat and secure full control over Tennessee's congressional delegation.
- [7]TN governor signs new congressional map into law, dividing Memphiswsmv.com
Governor Lee signed the new congressional map into law on May 7, marking the end of the three-day special session.
- [8]Tenn. GOP to limit public input on redrawing U.S. House map as protesters descend on Capitoltennesseelookout.com
Republicans limited public testimony during the special session as hundreds of protesters gathered at the Tennessee State Capitol.
- [9]Republicans unveil proposed congressional map that carves up Tennessee's lone Democratic districtnbcnews.com
The map divides Memphis into three districts, spreading Democratic voters into rural Republican districts stretching hundreds of miles east.
- [10]NAACP sues to stop Tennessee GOP gerrymander that dismantles majority-Black districtdemocracydocket.com
The NAACP filed an emergency lawsuit arguing the map violates Tennessee state law and the state constitution, challenging the repeal of the mid-decade redistricting ban.
- [11]Congressional redistricting targets Memphis, sparks protestsnashvillebanner.com
Three arrests were made during Capitol protests. Rep. Justin Jones handed a Confederate flag printout to the Majority Leader. Sen. Oliver unfurled a protest banner from her desk.
- [12]Allen v. Milligan: Supreme Court Holds That Alabama Redistricting Map Likely Violated Section 2 of the Voting Rights Actcongress.gov
The Supreme Court ruled 5-4 in 2023 that Alabama's congressional map likely violated Section 2 of the VRA, reaffirming the Gingles preconditions for vote dilution claims.
- [13]The U.S. Supreme Court Has Eviscerated the Voting Rights Act — What's Next?campaignlegal.org
By ruling that race-conscious compliance is unconstitutional, the Callais Court hollowed out Section 2's central enforcement mechanism.
- [14]Tennessee approves new congressional map in latest redistricting flurryaljazeera.com
Multiple states moved simultaneously on redistricting after the Callais ruling, including Louisiana, Alabama, Mississippi, and others.
- [15]Shaw v. Reno (1993)justia.com
The Supreme Court ruled that redistricting based predominantly on race is subject to strict scrutiny under the Equal Protection Clause.
- [16]TN Legislature Passes Redistricted Map. Mississippi's Next.hotair.com
Tennessee became the first state to pass a new map after the Callais ruling. Mississippi is expected to follow.
- [17]NAACP Tennessee files lawsuit challenging redrawn US House district maptennesseelookout.com
NAACP Tennessee President Gloria Sweet-Love filed an emergency petition in Davidson County Chancery Court to block the new map.
- [18]Tennessee Democrats rebuke 'racist' new gerrymander as GOP begins sessiondemocracydocket.com
Martin Luther King III warned the redistricting would dismantle hard-won civil rights protections. Rev. Earle Fisher said it's about whether Black voices will be heard or hidden.
- [19]Tennessee's 9th congressional districtwikipedia.org
Tennessee's 9th congressional district has been the state's sole majority-minority district, centered on Memphis with approximately 60% Black voting-age population.