Federal Court Strikes Down Georgia's Congressional Map — Again
The 11th Circuit upheld a lower court ruling that Georgia's 2023 congressional redistricting violated the Voting Rights Act. The state now has until September to draw new maps.
Sunday, May 18, 2025
A federal appeals court upheld a district court ruling that Georgia’s 2023 congressional redistricting plan diluted Black voting power in violation of Section 2 of the Voting Rights Act, giving the state until September 15 to submit remedial maps.
The ruling is significant for several reasons — not least because it is the second consecutive Georgia congressional map struck down by the same court on the same grounds. The 11th Circuit’s decision signals that courts are prepared to apply genuine scrutiny to maps drawn by Republican legislatures in majority-minority districts.
What the court found
The district court found that Georgia’s map cracked the Black voting-age population in the Atlanta suburbs across multiple districts in a way that prevented Black voters from electing their preferred candidates in a second Congressional seat. The remedial order requires Georgia to create a second majority-Black congressional district.
The state argued that population growth and residential sorting, not racial intent, explained the map’s configuration. The court rejected that argument, finding that the state’s mapmakers had precise racial data available and used it.
The Merrill v. Milligan shadow
The ruling follows the Supreme Court’s 2023 decision in Merrill v. Milligan, which reaffirmed that Section 2 requires states to draw majority-minority districts when certain conditions are met. That ruling was widely seen as a surprise given the Court’s recent direction on voting rights — and state legislatures across the South have been testing its boundaries ever since.
Georgia is now the second state after Alabama to have a post-Merrill remedial map imposed by a court. The pattern suggests that Republican legislatures are drawing maps that test the legal line and accepting the litigation as a feature, not a bug — maps stay in effect through at least one election cycle while cases proceed.
What new maps mean for 2026
Georgia currently has 9 Republican and 5 Democratic members of Congress. A second majority-Black district almost certainly flips one Republican seat. That single seat could matter enormously in a 2026 cycle where Democrats need a net gain of a handful of seats to reclaim the House.
The state has until September 15. If the legislature fails to pass a remedial map, the court has indicated it will appoint a special master to draw one.