Tennessee's Race to Erase: How a Supreme Court Ruling Launched a Southern Redistricting Blitz

On the evening of Friday, May 1, 2026, Tennessee Governor Bill Lee issued a terse proclamation: state lawmakers would return to Nashville on Tuesday to redraw the state's congressional district map [1]. The announcement came less than 72 hours after the U.S. Supreme Court handed down its 6-3 decision in Louisiana v. Callais, a ruling that gutted Section 2 of the Voting Rights Act and removed the legal requirement for states to create majority-minority congressional districts [2]. The speed was extraordinary. The regular legislative session had wrapped up less than two weeks earlier [1].

The target was obvious: Tennessee's 9th Congressional District, a majority-Black, Memphis-based seat held by Democratic Rep. Steve Cohen since 2007, and the only remaining Democratic district in the state [3]. Republicans, who already hold eight of Tennessee's nine House seats, want all nine.

"We owe it to Tennesseans to ensure our congressional districts accurately reflect the will of Tennessee voters," Lee said in a statement [4]. Critics saw it differently. State Senate Democratic Leader Raumesh Akbari called it "voter disenfranchisement" and "voting discrimination, full stop" [5].

The Supreme Court Ruling That Opened the Floodgates

The Louisiana v. Callais decision, issued April 29, 2026, rewrote the rules of redistricting law in the United States [2]. The case originated in Louisiana, where a federal district court had found the state's 2022 congressional map likely violated Section 2 of the Voting Rights Act because it failed to include a second majority-Black district. Louisiana drew a new map with two majority-Black districts — but that remedial map was then challenged as a racial gerrymander [6].

In a 6-3 decision split along ideological lines, the Supreme Court sided with the challengers. Justice Samuel Alito, joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett, held that race-conscious redistricting under Section 2 amounts to an unconstitutional racial gerrymander under the Equal Protection Clause [2][6]. The ruling significantly reworked the framework established in Thornburg v. Gingles (1986), the 40-year-old precedent that had governed Voting Rights Act redistricting claims [7].

Under the new standard, plaintiffs challenging a map as discriminatory must demonstrate a "strong inference" of intentional discrimination — a much higher bar than the previous effects-based test [8]. Justice Elena Kagan, in dissent, warned that the approach "risks unraveling decades of civil rights protections" and that ignoring "the real-world operation of racial discrimination does not produce neutrality — it entrenches inequality" [9].

The practical implications are sweeping. Analysts at the Campaign Legal Center estimated that up to a quarter of Congressional Black Caucus seats and roughly a tenth of Congressional Hispanic Caucus seats could be affected by map changes that would previously have triggered Section 2 scrutiny [7]. Democratic Rep. Troy Carter of Louisiana warned the ruling "can impact up to 19 or 20 seats in the congressional Black Caucus" [10].

What the Tennessee Map Would Change

Tennessee currently sends eight Republicans and one Democrat to Congress. The lone Democratic seat, the 9th District, covers most of Memphis and parts of Shelby County. With a Cook Partisan Voting Index of D+23, it is a safe Democratic district with a majority-Black population [11]. Tennessee's Black population stands at approximately 16-17% of the state — more than one-ninth of all residents [3].

The proposed new map, previewed by U.S. Senator Marsha Blackburn — who is running for governor — would "crack" Memphis by splitting its heavily Democratic, predominantly Black population across multiple Republican-leaning districts [3][12]. One version of the map would create an oddly shaped district stretching from Memphis to Chattanooga along the state's southern border [4]. The result: no district in the state where Black voters or Democrats could elect a candidate of their choosing.

Source: Ballotpedia / Tennessee Secretary of State

Data as of May 4, 2026CSV

This follows a playbook Tennessee Republicans used in the 2022 redistricting cycle. During that round, the legislature split Davidson County (Nashville) across three congressional districts, eliminating what had been a safe Democratic seat [13]. The move prompted longtime Democratic Rep. Jim Cooper to retire. A federal appeals court later ruled the Nashville split was a partisan gerrymander but not a racial one — and since federal courts do not prohibit partisan gerrymandering, the map stood [14].

The redistricting special session costs taxpayers approximately $58,576 per day, covering per diem pay and transportation for all 132 legislators. Per diem pay for House members alone runs more than $24,000 daily, with nearly $20,000 in daily transportation costs [15]. A multi-day session could easily run into the hundreds of thousands of dollars — the last four-day special session in 2023 cost nearly $300,000 [15].

The Trump Factor

The special session did not emerge in a vacuum. President Donald Trump publicly inserted himself into the redistricting push. After the Callais ruling came down, Trump indicated that Tennessee should be among the next states to redraw its maps [16]. Governor Lee, who is term-limited and leaving office after 2026, called the session after what was described as a conversation with Trump [1].

Blackburn's proposed map circulated days before Lee's official announcement, suggesting coordination between federal and state Republican officials [12]. The sequence — a Supreme Court ruling on Tuesday, a senator's proposed map by Wednesday, a presidential endorsement the same day, and a gubernatorial proclamation by Friday — moved faster than any previous redistricting effort in the state's history.

Mid-Decade Redistricting: Rare but Not Unprecedented

Voluntary mid-decade redistricting for partisan purposes is extremely uncommon. According to Pew Research Center data, only three states since 1970 have voluntarily redrawn congressional maps between censuses for partisan advantage: Texas (2003 and 2025), Georgia (2005), and California (1982) [17]. The overwhelming majority of mid-cycle changes — 36 of 40 since 1970 — have resulted from court orders, not legislative choice [17].

The most relevant precedent is Texas in 2003, when then-House Majority Leader Tom DeLay orchestrated a mid-decade redraw that netted Republicans six additional House seats in the 2004 elections. The Supreme Court upheld that effort in LULAC v. Perry (2006), with Justice Anthony Kennedy writing that neither the Constitution nor federal law prohibits mid-decade redistricting [18].

North Carolina presents a contrasting case. The state has cycled through nine maps since 1990, with courts repeatedly striking down districts as unconstitutional racial gerrymanders [17]. North Carolina is also one of at least three states — along with New York and, notably, Tennessee — that specifically prohibit mid-decade congressional redistricting under state law, according to the National Conference of State Legislatures [18].

This raises an immediate legal question: if Tennessee's own laws restrict mid-decade redistricting, how is the special session proceeding? The answer lies in the distinction between routine partisan redistricting and redistricting in response to a change in federal law. Republican legislators argue the Callais ruling constitutes a material change in the legal landscape that justifies — even requires — a new map [4].

Who Loses Representation

The district most directly affected is the 9th, where Black residents make up a majority of the population. Memphis, the state's second-largest city and the core of the district, is approximately 64% Black [11]. Under the proposed map, these voters would be distributed across districts dominated by whiter, more rural, and more Republican electorates.

State Rep. Justin Pearson put it bluntly: "We deserve to be able to choose our own representation" [4].

The mathematics are stark. Black Tennesseans constitute roughly 16-17% of the state's population — comfortably more than one-ninth of all residents. Under current maps, they have meaningful influence in one of nine districts (11%). Under the proposed map, they would have meaningful influence in zero of nine districts (0%) [3].

Defenders of the remap argue that the Callais ruling simply requires states to stop using race as a predominant factor in drawing districts. They contend that the current 9th District was itself a form of racial gerrymandering — a district drawn primarily around race rather than communities of interest, compactness, or other neutral criteria [6]. From this perspective, eliminating the majority-minority district is not stripping representation but ending an unconstitutional racial classification.

Some redistricting analysts have noted that Tennessee's population has shifted since the 2020 census, with suburban growth around Nashville and Knoxville outpacing growth in Memphis [13]. Equal-population requirements could, in theory, justify adjustments to district boundaries. However, no nonpartisan redistricting organization has endorsed the specific maps circulated by Blackburn, and the stated goal of achieving a "9-0" Republican delegation undercuts claims of neutral motivation.

The Southern Redistricting Wave

Tennessee is not acting alone. Within days of the Callais ruling, at least five southern states signaled plans to redraw their congressional maps [10].

Source: CBS News analysis

Data as of May 4, 2026CSV

Louisiana suspended its May 16 House primaries and may revert to a map with just one Black-majority district instead of two, potentially gaining one to two Republican seats [10].

Florida advanced a map proposed by Governor Ron DeSantis that would eliminate or shrink Democratic-leaning districts in Tampa, Orlando, and the southeast, a potential four-seat Republican gain [10].

Alabama called a special session to prepare for possible redraws of its two majority-Black districts, though the state's own judicial appeal remains pending [19].

Mississippi Governor Tate Reeves announced a redistricting session for May 20, targeting the state's one remaining majority-Black district [10].

Georgia Governor Brian Kemp said changes would not affect 2026 but that the state's five-seat Democratic delegation could be reduced to three in 2028 [19].

CBS News estimated that if all these states succeeded, Republicans could gain between one and nine additional House seats for the 2026 midterms, with further gains possible in 2028 [10].

Legal Challenges Ahead

The Callais ruling made it harder to challenge redistricting maps, but it did not make it impossible. Several legal avenues remain.

The Purcell Principle: Federal courts have historically refused to alter election rules too close to an election. Tennessee's congressional primaries are scheduled for August 6, and the qualifying deadline has already passed [1]. Any new map imposed months before an election could face a Purcell challenge arguing that the disruption to voters, candidates, and election administrators is too great [10].

State constitutional claims: The Tennessee Supreme Court has previously rejected attempts to delay qualifying deadlines, citing military ballot requirements and election administration concerns [4]. If the new map requires resetting the primary calendar, state courts could block it on procedural grounds.

Remaining federal claims: While Callais raised the bar for Section 2 challenges, it did not eliminate them entirely. Plaintiffs can still prevail by demonstrating intentional racial discrimination — a harder standard, but not an insurmountable one if the legislative record shows that race was a motivating factor [8]. The explicit public statements about targeting a "majority-Black district" could become evidence in such a case.

Democracy Docket, the litigation organization led by Democratic election lawyer Marc Elias, has already signaled it is monitoring the Tennessee session for potential legal action [8]. The NAACP Legal Defense Fund has been involved in redistricting litigation across the South and is likely to participate in any challenge [2].

The realistic timeline is tight. For any legal challenge to affect the 2026 elections, a court would need to issue an injunction within weeks of the new map's passage. Given the August 6 primary date, litigation would need to move at an extraordinary pace — or courts would need to order the primaries delayed, which raises its own set of legal and logistical complications.

Campaign Money and Political Incentives

Tennessee's congressional races have attracted significant outside spending in recent cycles. In a 2025 special election for the 7th District alone, super PACs spent approximately $7 million, with MAGA Inc. contributing more than $1 million to the Republican candidate [20]. The Republican Party of Tennessee and allied PACs have invested heavily in maintaining the party's dominance across the state's eight GOP-held districts [20].

The decision to redistrict now, rather than waiting for the 2030 census cycle, reflects both opportunity and urgency. The Callais ruling provides legal cover that did not exist before April 29. The 2026 midterms present an immediate chance to flip the last Democratic seat. And Governor Lee, who cannot run again, faces no electoral consequences for calling the session.

Election-law scholars note that the relationship between campaign spending and redistricting is symbiotic. Redrawing maps to make districts safer reduces the need for expensive competitive campaigns, freeing up resources for other races. A 9-0 Tennessee map would effectively end competitive congressional elections in the state, redirecting Republican campaign dollars elsewhere [10].

What Happens Next

The special session convenes May 5. Republican leaders have indicated they want to move quickly — potentially passing a new map within days [4]. With supermajorities in both chambers (75-24 in the state House and a comparable margin in the Senate), passage is all but certain if Republican members remain united [1].

The open questions are legal, not legislative. Whether courts will allow a new map to take effect before the August primaries, whether the Purcell principle will freeze the current boundaries in place for 2026, and whether the legislative record created during the special session will provide enough evidence of discriminatory intent to sustain a legal challenge under the Callais framework — these are the fights that will determine whether Tennessee's 9th District survives.

For Memphis's Black community, the stakes are concrete. The 9th District has sent a representative of their choosing to Congress for decades. Under the proposed map, that voice disappears — not because of population shifts or neutral redistricting principles, but because the Supreme Court removed the legal barrier that prevented it.