{"id":255,"date":"2026-06-24T14:13:00","date_gmt":"2026-06-24T14:13:00","guid":{"rendered":"https:\/\/americanservicereview.com\/?p=255"},"modified":"2026-06-24T14:13:00","modified_gmt":"2026-06-24T14:13:00","slug":"the-blast-radius-of-callais-and-what-it-means-for-constitutional-law","status":"publish","type":"post","link":"https:\/\/americanservicereview.com\/?p=255","title":{"rendered":"The blast radius of Callais \u2013 and what it means for Constitutional Law"},"content":{"rendered":"
\n

In the month and a half since the Supreme Court decided Louisiana v. Callais<\/em>, the actual and potential scope of that case\u2019s destructive impact on the Reconstruction Amendments and on congressional power has only become clearer. As a reminder, in Callais<\/em>, the Supreme Court effectively overruled Section 2 of the Voting Rights Act, which prohibited voting practices with racially discriminatory effects<\/em>, even in the absence of discriminatory intent. More specifically, Callais<\/em> held that Congress lacks the power to outlaw voting practices resulting in discriminatory effects except where the circumstances \u201cgive rise to a strong inference of racial discrimination.\u201d The vast impact of that opinion is becoming clear not only when it comes to voting rights but also in other forms of discrimination law.<\/p>\n

Read more When Congress \u201coverrides\u201d the court<\/a><\/p>\n

Minority voting rights<\/strong><\/p>\n

Congress enacted the current version of Section 2 in part to ensure that minority voters are able to have meaningful representation in multimember elected bodies. But the court appears to believe that purpose itself to be unconstitutional. Intentional racial discrimination in voting and election law violates the 14th and 15th Amendments, and the Supreme Court is now treating efforts to protect<\/em> minority voters\u2019 electoral influence as constitutionally equivalent to efforts to undermine it. Barely a month after deciding Callais<\/em>, the court invoked \u201cour colorblind constitution\u201d in a shadow docket ruling Alabama to eliminate the congressional district that a district court had ordered to remedy racial discrimination. That per curiam opinion, Allen v. Milligan<\/em>, from which the three liberal justices dissented, effectively reversed the court\u2019s own 2023 merits opinion in the very same litigation.<\/em> (Alabama is not alone. Several other southern states have redistricted in ways that eliminate or reduce minority voters\u2019 electoral power.)<\/p>\n

At least as alarming is that the Allen<\/em> shadow docket opinion also rejected the district court\u2019s factual finding that Alabama intentionally <\/em>discriminated against Black voters. Callais<\/em> itself claimed not to be addressing intentional discrimination, only cases about discriminatory effects in redistricting. But it is now clear that this claim, barely credible to begin with, was false. In Allen, <\/em>the court expanded on Callais<\/em>\u2019 new requirement that a voting rights plaintiff alleging disparate impact in redistricting produce an alternative map that performs \u201cjust as well\u201d as the state\u2019s map \u201cwith respect to all<\/em> of the state\u2019s constitutionally permissible criteria.\u201d The court combined that new standard with demanding a presumption of \u201clegislative good faith\u201d in redistricting cases alleging intentional discrimination. That combination, as applied in Allen<\/em>, suggests that once a state claims any<\/em> constitutionally permissible basis for its map, the case may be functionally over. Plaintiffs may not even be allowed to try to demonstrate that the claimed \u201cpermissible basis\u201d is a pretext for intentional discrimination. Whether they can proceed to that stage will depend on whether they can produce an alternative map that meets Callais<\/em>\u2019 new \u201cjust-as-well\u201d standard.<\/p>\n

Indeed, the Allen <\/em>court barely mentioned the district court\u2019s analysis of the extensive evidence of racial discrimination. The Supreme Court ignored, for example, the district court\u2019s detailed findings that Alabama had deviated significantly from its prior redistricting practices and criteria. And it even credited as a constitutionally permissible<\/em> purpose Alabama\u2019s desire to keep intact a district that encompasses the Gulf Coast despite the state\u2019s express reliance on that area\u2019s \u201cFrench and Spanish colonial heritage.\u201d (In other words, according to Allen<\/em>, it\u2019s constitutionally permissible for the state to take into account a community\u2019s white European heritage in drawing its map.) As Justice Sonia Sotomayor said in dissent, if the district court clearly erred by finding discriminatory intent here, \u201cthere is no realistic case in which the presumption of legislative good faith can ever be rebutted.\u201d Cases in which the circumstances \u201cgive rise to a strong inference of racial discrimination,\u201d as demanded by Callais<\/em>, may thus be a null set.<\/p>\n

So Callais<\/em> has decimated voting rights protections for minorities. But perhaps only for minorities. In the past, the court has required plaintiffs alleging intentional discrimination in redistricting to show that consideration of race \u201cpredominated\u201d over other factors. Callais<\/em>, on the other hand, suggests that any<\/em> desire to protect or perhaps even consider minority voting power is unconstitutional. We may well see a wave of new racial gerrymandering claims brought by white voters challenging their districts on that basis. One wonders whether or how the \u201cpresumption of legislative good faith\u201d will apply in such cases.<\/p>\n

Callais<\/em>\u2019 impact on the law of employment discrimination<\/strong><\/p>\n

Up next may be employment discrimination, at least if the Department of Justice\u2019s Office of Legal Counsel has its way. (OLC \u201cprovides legal advice to the President and all executive branch agencies.\u201d It does not have the power to actually change the law.) On June 9, 2026, OLC issued an opinion entitled \u201cConstitutionality of Disparate-Impact Liability Under Title VII.\u201d In reliance on Callais<\/em> and the new version of Allen<\/em>, OLC purports to declare unconstitutional existing law outlawing (under some circumstances) employment practices that have discriminatory effects. In so doing, it attempts to wipe aside decades of Supreme Court precedent and Congress\u2019 own decision, in 1991, to codify prohibitions on facially neutral employment practices that exclude protected groups but are not tied to job performance.<\/p>\n

By way of background, everyone \u2013 including OLC \u2013 agrees that as enacted in 1964, Title VII outlaws intentional<\/em> discrimination on the basis of race and other protected characteristics. In 1971, in a case called Griggs v. Duke Power Co.<\/em>, the Supreme Court held that under some circumstances, Title VII also outlaws practices with a discriminatory effect<\/em> even in the absence of intentional discrimination.<\/p>\n

The facts of Griggs<\/em> are instructive (although simplified here). Before Title VII was enacted, Duke Power, based in North Carolina, had an entirely segregated workforce. African Americans could work only in the Labor Department, one of five \u201coperating departments,\u201d and the one that paid the least. After Title VII went into effect, Duke Power eliminated that restriction but imposed several new requirements. For some jobs, it began to require a \u201cpassing\u201d performance on two tests, one that purported to measure \u201cgeneral intelligence\u201d and the other apparently addressing \u201cmechanical comprehension.\u201d The tests had the effect of screening out almost all of the African Americans seeking jobs outside the Labor Department. Duke Power did not claim that these tests measured any skills or abilities necessary for the jobs in question or even for being trained to do those jobs. Instead, it said only that it thought the tests \u201cgenerally would improve the overall quality of the work force.\u201d Nonetheless, the district court found no intentional discrimination.<\/p>\n

In Griggs<\/em>, the Supreme Court held, 8-0, that Duke Power violated Title VII because it engaged in an employment practice \u2013 the test requirement \u2013 that had the effect of excluding African Americans from its workforce. It explained that Title VII \u201cproscribes not only overt discrimination but also practices that are fair in form, but discriminatory in operation. The touchstone is business necessity. If an employment practice which operates to exclude Negroes cannot be shown to be related to job performance, the practice is prohibited.\u201d<\/p>\n

Read more What to know about the court\u2019s five latest rulings<\/a><\/p>\n

In its June 9, 2026, memo, OLC tries to rewrite Griggs<\/em>, saying that \u201c[t]he trial court\u2019s findings were controversial, considering\u201d the evidence in the record of discriminatory intent. Of course, it may well be true as a factual matter that Duke Power intentionally discriminated against African Americans. But that is not, remotely, the basis on which the Supreme Court decided Griggs<\/em>. The court was very explicit that it was addressing Title VII liability in the absence of<\/em> discriminatory intent<\/em>.<\/p>\n

The OLC opinion also tries to rewrite what Congress did. It claims that Congress \u201cacquiesced in [Griggs<\/em>\u2019]interpretation when it amended Title VII in 1991,\u201d as if Congress acted only begrudgingly. But that is not correct (nor would it matter if it were given the actual amendment that Congress passed). Rather, when Congress amended Title VII in 1991, it did so in part to override a 1989 case called Wards Cove Packing Co. v. Atonio<\/em>. Among other things, Wards Cove<\/em> had \u201cdilute[d] the \u201cnecessity\u201d in the \u201cbusiness necessity\u201d defense,\u201d focusing instead on \u201cthe employer’s legitimate interests,\u201d a much lower bar than Griggs<\/em> had required.<\/p>\n

Congress rejected Wards Cove<\/em>. In the Civil Rights Act of 1991 itself, Congress stated that one of the statute\u2019s \u201cpurposes\u201d was \u201cto codify the concepts of \u2018business necessity\u2019 and \u2018job related\u2019 enunciated by the Supreme Court in Griggs \u2026 and in the other Supreme Court decisions prior to Wards Cove <\/em>\u2026\u201d (my emphasis). And to operationalize that purpose, Congress added an entire subsection to Title VII laying out how disparate impact claims operate and incorporating the language of Griggs<\/em>. If a plaintiff shows that a particular employment practice has discriminatory effects, Congress said, the employer must then \u201cdemonstrate that the challenged practice is job related for the position in question and consistent with business necessity.\u201d<\/p>\n

In other words, Congress did not \u201cacquiesce\u201d to Griggs<\/em>. It doubled down.<\/p>\n

But, despite Congress\u2019 clear words to the contrary, OLC relies on Callais<\/em> to try to undo all of that. It argues that disparate impact law, dating back to 1971, needs to be \u201cupdate[d]\u201d to eliminate constitutional concerns, just as Callais <\/em>purported to \u201cupdate\u201d voting rights law. Specifically, it quotes Callais<\/em> to argue that Title VII\u2019s disparate impact prohibition is unconstitutional under the 14th Amendment\u2019s equal protection clause unless it is limited to situations that \u201cgive rise to an objectively \u2018strong inference\u2019 of intentional discrimination.\u201d Based on OLC\u2019s updated interpretation, employment practices need only be \u201creasonably related to the achievement of some legitimate goal\u201d to be valid because that reasonable relationship\u201d necessarily \u201cdispels an inference\u201d of discriminatory intent.<\/p>\n

Moreover, OLC specifically identifies \u201captitude tests\u201d and \u201cknowledge-based tests\u201d as \u201cpresumptively job-related.\u201d Under this standard, of course, Griggs<\/em> would have come out the other way. In other words, OLC is arguing both for overruling the key holding of Griggs<\/em> and for eviscerating the central provision of the 1991 Civil Rights Act that codified that holding. It is arguing that Congress has no power to legislate against race discrimination in the very way Congress expressly chose to do so<\/em>.<\/p>\n

And just as Callais <\/em>and Allen<\/em> will make protecting minority voting rights all but impossible, OLC\u2019s analysis, if adopted by the courts, could actually encourage employers to adopt or keep in place tests and screening mechanisms that have a disparate impact on minorities. In a footnote, OLC asserts that \u201cracial or ethnic diversity cannot be a legitimate business goal that defeats a disparate-impact challenge to a facially neutral policy.\u201d The implications of this position are astonishing. Imagine an employer who is deciding which test or screening criteria to use in hiring employees. If it chooses one with a less disparate impact on minorities, in part for that reason, has it then violated Title VII? After all, white plaintiffs could claim that the chosen test has a disparate impact on them<\/em> \u2013 or that any consideration of disparate impact on minorities has this effect and may even rise to the level of intentional discrimination. Those outcomes are not what Title VII says or what Congress intended, but they may well be what OLC demands is required.<\/p>\n

What Callais<\/em>\u2019 impact means for how we think about Constitutional Law<\/strong><\/p>\n

There is much more (and in my opinion, nothing good) to say about how the OLC opinion, if adopted by the Supreme Court, would undermine both congressional power and longstanding law. But I want to zoom out a bit here. Callais<\/em> is only one of numerous cases in which this court has dramatically changed the law or appears about to do so. Whether one celebrates or condemns those cases, that fact is undeniable.<\/p>\n

But that fact also should remind us that these new holdings are not necessarily permanent. As I\u2019ve argued elsewhere, change in constitutional law is nothing new. (Think Plessy v. Ferguson<\/em> and Brown v. Board of Education<\/em>.) That\u2019s not to understate the deeply destructive nature of many of this court\u2019s decisions and the significant harm they inflict on real people. Nor is it to understate the very long time horizons and massive political and social mobilization involved in constitutional change, nor the fact that the court\u2019s appalling voting and election law jurisprudence may well extend those timeframes and require even more intense efforts. The point is simply this: constitutional law is changing dramatically. It can change again.<\/p>\n

Read more Court sides with government in dispute over rights of green card holders accused of committing a crime<\/a><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

In the month and a half since the Supreme Court decided Louisiana v. Callais, the actual and potential scope of that case\u2019s destructive impact on the Reconstruction Amendments and on congressional power has only become clearer. 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