Louisiana v. Callais · ¶33

The first case in which the Court explicitly made this assumption was Miller v. Johnson, 515 U. S. 900, 917–920 (1995),which concerned a majority-black district that was designed to satisfy the Justice Department's preclearance demands under § 5 of the Voting Rights Act. The Miller Court first found that the legislature had “subordinated traditional race-neutral districting principles, including but not limited to compactness, contiguity, and respect for political subdivisions or communities defined by actual shared interests, to racial considerations.” Id., at 916. For this reason, the Court held, race had predominated in the creation of the new district, and the State had to “demonstrate that its districting legislation [wa]s narrowly tailored to achieve a compelling interest.” Id., at 920. The Court declined to address “[w]hether or not in some cases compliance with the [Voting…

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