The United States Supreme Court, led by Chief Justice John Roberts, who has spent much of his legal career narrowing the scope of the 1965 Voting Rights Act has continued that trajectory in the Courts 6–3 decision in Louisiana v. Callais, further weakening protections long used to safeguard Black voting power and representation.
The ruling holds that race-conscious districting designed to ensure minority representation is unconstitutional. At the same time, the Court has previously permitted partisan gerrymandering. In the American South, where race and party affiliation are deeply intertwined, this dual framework will predictably diminish Black political representation on all levels of government.
Immediately after the ruling, Florida advanced a congressional map projected to reduce Democratic-held seats. Alabama and Louisiana signaled plans to redraw maps that will certainly eliminate Black congressional districts. In Tennessee, Senator Marsha Blackburn urged state legislators to eliminate Democratic representation in Memphis, a majority-Black city.
Regardless of how the majority frames its reasoning, this decision effectively undermines a law that Congress has reauthorized repeatedly and that has long served as a cornerstone of Black suffrage. From a critical perspective, the ruling can be read as prioritizing partisan entrenchment over equitable representation for Black voters.
For deeper analysis of this decision’s implications for Black voters, representation and American democracy, see the recent work of Adam Serwer (Voters Can Be Disenfranchised Now), Elie Mystal (The Supreme Court Has Completed Its Quest to Kill the Voting Rights Act), and Sherrilyn Ifill (SCOTUS Drops The Other Shoe on the Voting Rights Act).
This moment is not without precedent.
The right to vote for Black Americans was not granted cleanly through legislation alone, it was fought for and in many cases, paid for in blood.
For this essay, I want to highlight some of the men and women whose bodies were beaten and broken in the struggle to make the Voting Rights Act of 1965 a reality. These individuals were martyrs in the fight for fair and equal political participation—sacrifices this court has disparaged and disregarded in their Callais ruling.
Benjamin F. Randolph, a Black state senator and advocate for Black voting rights in South Carolina, was assassinated in 1868 by white supremacists.
George W. Ashburn, a white Republican who supported Black suffrage, was assassinated in 1868 by the Ku Klux Klan.
Octavius Catto, a Black educator and civil rights activist, was one of many Black men killed on Election Day in Philadelphia in 1871 to suppress Black voters.
The Colfax Massacre in 1873 saw more than 100 Black men killed by white supremacists while defending a courthouse after a disputed election—one of the deadliest attacks on Black voting rights in U.S. history.
The Hamburg Massacre in 1876 similarly resulted in the deaths of Black citizens by white supremacist groups seeking to suppress Black political participation.
Harry T. Moore, an NAACP leader in Florida who organized voter registration drives, was killed in a 1951 bombing of his home alongside his wife, Harriette V. Moore—among the first martyrs of the modern Civil Rights Movement.
Herbert Lee was murdered in Mississippi in 1961 for assisting voter registration efforts alongside SNCC organizers.
Medgar Evers, NAACP field secretary in Mississippi, led voter registration efforts before being assassinated outside his home in 1963.
James Chaney, Andrew Goodman, and Michael Schwerner were murdered in 1964 during Freedom Summer in Mississippi for their work registering Black voters.
Jimmie Lee Jackson was shot by Alabama state troopers during a peaceful protest in Marion, Alabama, in 1965. His death helped catalyze the Selma-to-Montgomery marches.
Viola Liuzzo, a white ally from Michigan, was murdered by Klansmen in 1965 while transporting marchers during the Selma campaign.
The Selma to Montgomery marches were met with brutal violence—most notably “Bloody Sunday,” when state troopers attacked peaceful demonstrators advocating for voting rights.
These are only some of the named individuals who gave their lives for voting rights. They stand alongside the tens of thousands of Union soldiers whose deaths helped secure the 13th, 14th, and 15th Amendments and the countless unnamed individuals who were lynched, beaten, or disappeared in the fight for Black suffrage and equal rights.
Decisions like Callais raise fundamental questions about how seriously this history is treated in contemporary jurisprudence. Based on this Court’s recent voting rights rulings affecting Black Americans, one could reasonably conclude that this history carries little weight. The Court’s approach appears to prioritize preserving white political power structures over the protection of Black voting rights.
The ramifications of this ruling will unfold over time. To paraphrase W.E.B. Du Bois, Black Americans fought for the right to vote, stood briefly in that freedom, and are now being pushed back toward Jim Crow.
Yet, the history of these martyrs reminds us that regression is never permanent. Even in setback, there is opportunity—not only to defend rights that have been gained, but to build a more just and equitable society. The struggle continues, and the next battle, like so many before it—will be fought at the ballot box this November.
Publisher’s Note
Brandon J. Sutton is a U.S. History professor at the Community College of Baltimore County (CCBC). He holds a B.S. and Master of Applied Social Science in Political Science from Florida A&M University, as well as a Master of Divinity from Liberty University.
The views expressed in this essay are those of the author and are intended as analysis and interpretation based on publicly available information, historical scholarship, and contemporary commentary. This piece reflects opinion and should not be construed as a statement of objective fact regarding the intent of any individual or institution.
The ruling holds that race-conscious districting designed to ensure minority representation is unconstitutional. At the same time, the Court has previously permitted partisan gerrymandering. In the American South, where race and party affiliation are deeply intertwined, this dual framework will predictably diminish Black political representation on all levels of government.
Immediately after the ruling, Florida advanced a congressional map projected to reduce Democratic-held seats. Alabama and Louisiana signaled plans to redraw maps that will certainly eliminate Black congressional districts. In Tennessee, Senator Marsha Blackburn urged state legislators to eliminate Democratic representation in Memphis, a majority-Black city.
Regardless of how the majority frames its reasoning, this decision effectively undermines a law that Congress has reauthorized repeatedly and that has long served as a cornerstone of Black suffrage. From a critical perspective, the ruling can be read as prioritizing partisan entrenchment over equitable representation for Black voters.
For deeper analysis of this decision’s implications for Black voters, representation and American democracy, see the recent work of Adam Serwer (Voters Can Be Disenfranchised Now), Elie Mystal (The Supreme Court Has Completed Its Quest to Kill the Voting Rights Act), and Sherrilyn Ifill (SCOTUS Drops The Other Shoe on the Voting Rights Act).
This moment is not without precedent.
The right to vote for Black Americans was not granted cleanly through legislation alone, it was fought for and in many cases, paid for in blood.
For this essay, I want to highlight some of the men and women whose bodies were beaten and broken in the struggle to make the Voting Rights Act of 1965 a reality. These individuals were martyrs in the fight for fair and equal political participation—sacrifices this court has disparaged and disregarded in their Callais ruling.
Benjamin F. Randolph, a Black state senator and advocate for Black voting rights in South Carolina, was assassinated in 1868 by white supremacists.
George W. Ashburn, a white Republican who supported Black suffrage, was assassinated in 1868 by the Ku Klux Klan.
Octavius Catto, a Black educator and civil rights activist, was one of many Black men killed on Election Day in Philadelphia in 1871 to suppress Black voters.
The Colfax Massacre in 1873 saw more than 100 Black men killed by white supremacists while defending a courthouse after a disputed election—one of the deadliest attacks on Black voting rights in U.S. history.
The Hamburg Massacre in 1876 similarly resulted in the deaths of Black citizens by white supremacist groups seeking to suppress Black political participation.
Harry T. Moore, an NAACP leader in Florida who organized voter registration drives, was killed in a 1951 bombing of his home alongside his wife, Harriette V. Moore—among the first martyrs of the modern Civil Rights Movement.
Herbert Lee was murdered in Mississippi in 1961 for assisting voter registration efforts alongside SNCC organizers.
Medgar Evers, NAACP field secretary in Mississippi, led voter registration efforts before being assassinated outside his home in 1963.
James Chaney, Andrew Goodman, and Michael Schwerner were murdered in 1964 during Freedom Summer in Mississippi for their work registering Black voters.
Jimmie Lee Jackson was shot by Alabama state troopers during a peaceful protest in Marion, Alabama, in 1965. His death helped catalyze the Selma-to-Montgomery marches.
Viola Liuzzo, a white ally from Michigan, was murdered by Klansmen in 1965 while transporting marchers during the Selma campaign.
The Selma to Montgomery marches were met with brutal violence—most notably “Bloody Sunday,” when state troopers attacked peaceful demonstrators advocating for voting rights.
These are only some of the named individuals who gave their lives for voting rights. They stand alongside the tens of thousands of Union soldiers whose deaths helped secure the 13th, 14th, and 15th Amendments and the countless unnamed individuals who were lynched, beaten, or disappeared in the fight for Black suffrage and equal rights.
Decisions like Callais raise fundamental questions about how seriously this history is treated in contemporary jurisprudence. Based on this Court’s recent voting rights rulings affecting Black Americans, one could reasonably conclude that this history carries little weight. The Court’s approach appears to prioritize preserving white political power structures over the protection of Black voting rights.
The ramifications of this ruling will unfold over time. To paraphrase W.E.B. Du Bois, Black Americans fought for the right to vote, stood briefly in that freedom, and are now being pushed back toward Jim Crow.
Yet, the history of these martyrs reminds us that regression is never permanent. Even in setback, there is opportunity—not only to defend rights that have been gained, but to build a more just and equitable society. The struggle continues, and the next battle, like so many before it—will be fought at the ballot box this November.
Publisher’s Note
Brandon J. Sutton is a U.S. History professor at the Community College of Baltimore County (CCBC). He holds a B.S. and Master of Applied Social Science in Political Science from Florida A&M University, as well as a Master of Divinity from Liberty University.
The views expressed in this essay are those of the author and are intended as analysis and interpretation based on publicly available information, historical scholarship, and contemporary commentary. This piece reflects opinion and should not be construed as a statement of objective fact regarding the intent of any individual or institution.
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