Caster v. Allen

Following the victory of the NRF-supported Caster Plaintiffs in the landmark case Allen v. Milligan, which upheld a trial court’s injunction against Alabama’s 2021congressional map, the state responded by enacting a map that contained only one Black-opportunity district. This 2023 remedial map stood in defiance of federal law and orders from federal courts at every level that had demanded that Alabama comply with the Voting Rights Act (VRA) and produce a congressional map that contained two districts where Black voters had the opportunity to elect a candidate of their choice. The Caster Plaintiffs requested that the court temporarily enjoin the state’s 2023 remedial map as a likely violation of the VRA, which the court granted. Given the deficiencies in the state’s proposed remedial plan, the district court established a judicial process to select a remedial map for use in the 2024 elections. In that process, the court chose a fair map with two Black-opportunity districts drawn by an impartial special master. The state of Alabama continued to defy the requirements of the VRA, requiring NRF to continue the fight in court to ensure that all Alabamians have a fair and non-dilutive congressional map for future elections. The NRF-supported Caster Plaintiffs filed an amended complaint challenging the state’s proposed 2023 remedial congressional map plan as a violation of Section 2 of the VRA. Following a bench trial in February 2025, the trial court ruled that Alabama’s congressional map violated both the VRA and the Fourteenth Amendment of the U.S. Constitution. On August 7, 2025, the court enjoined the state from using its violative 2023 remedial map and requiring the state to use the special master’s map for the remainder of the decade. This order ensured that Black Alabamians had two congressional districts in which they have the opportunity to elect candidates of their choice.

Following the U.S. Supreme Court’s decision in Louisiana v. Callais, Alabama’s Secretary of State filed an emergency motion in district court to vacate the injunction against the state’s 2023 remedial map. The district court denied that motion, but, on May 11, 2026, the U.S. Supreme Court vacated the district court’s injunction and remanded the case. The NRF-supported Caster Plaintiffs then filed a motion for a temporary restraining order, and, on May 26, 2026, the district court granted it and enjoined Alabama from using its 2023 remedial map in the 2026 elections. The court found that that map still violated Section 2 of the VRA, even under the new Callais standard. On appeal, however, the U.S. Supreme Court vacated the injunction, thus allowing Alabama to use its 2023 remedial map—one which has only one Black-opportunity district—in the 2026 elections.

Case Documents

• First Amended Complaint (January 31, 2024)
• Injunction and Order, Findings of Fact and Conclusions of Law (May 8, 2025)
• Injunction and Final Judgment (August 7, 2025)
• Caster Respondents’ Response to Alabama’s Petition for Writ of Certioari Before Judgment (October 20, 2025)
• Caster Plaintiffs’ Motion for Preliminary Injunction and Memorandum in Support (May 15, 2026)
• Order Enjoining Alabama’s Use of the 2023 Remedial Map (May 26, 2026)
• Order Granting Stay of the Injunction of Alabama’s Use of the 2023 Remedial Map (June 2, 2026)