Louisiana v. Callais · ¶31

In later cases, redistricting plans that States created to comply with the Voting Rights Act were themselves challenged as racial gerrymanders. This Court approached such cases by building on the framework from other racial- discrimination cases under the Equal Protection Clause. In those cases, if race played a role in a decision made by a government actor, strict scrutiny applied. See Arling ton Heights, 429 U. S., at 265–266. Under this standard, the government needed to assert a compelling interest that justified its use of race; and if the analysis progressed beyond this point, the government had to show that its use of race was narrowly tailored to vindicate that interest. See, e. g., Students for Fair Admissions, Inc. v. President and Fellows of Harvard College, 600 U. S. 181, 206 (2023) (SFFA).

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