TN Map Splits Majority-Black District: 9-0 GOP Sweep Now Possible

For election law practitioners, the Tennessee panel’s denial of a preliminary injunction against the state’s new congressional map is a textbook application of the Supreme Court’s 2019 Rucho bar on partisan gerrymandering claims, now combined with the April 2026 Louisiana ruling that undermined the Voting Rights Act’s protections for majority-minority districts. The decision underscores the near-impossibility of prevailing on a racial gerrymandering claim when legislatures can point to a partisan alternative explanation, absent a ‘smoking gun’ showing racial animus. This legal standard is reshaping redistricting across the South, with eight states now embarking on mid-decade map redraws.

On July 23, 2026, a federal three-judge panel declined to enjoin Tennessee’s newly enacted congressional map, allowing the state to proceed with a plan that dismantles the only majority-Black district—centered in Memphis—and all but guaranteeing an all-Republican congressional delegation in this year’s midterm elections. The order, issued just two weeks before the August 6 primary, marks a crucial victory for GOP legislators who rushed to redraw the map in May following the U.S. Supreme Court’s April 2026 decision striking down a Louisiana majority-Black district as an illegal racial gerrymander. That ruling, Justice Department officials and voting rights advocates warned, would embolden states to dismantle minority opportunity districts under the guise of partisan intent—and Tennessee’s map and the court’s green light are the first dramatic illustration.

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Tennessee Republicans openly declared their goal: capture the state’s lone Democratic seat, the 9th Congressional District held by a Black Democrat, and deliver a 9–0 GOP sweep.

The legal dispute centers on the line between racial and partisan gerrymandering. Since the Supreme Court’s 2019 decision in Rucho v. Common Cause, federal courts are barred from hearing claims that a map is excessively partisan. Plaintiffs alleging racial discrimination must prove that race was the predominant motive and that traditional districting principles were subordinated to racial considerations—a high bar made even higher when state actors can point to a credible political rationale. Tennessee Republicans openly declared their goal: capture the state’s lone Democratic seat, the 9th Congressional District held by a Black Democrat, and deliver a 9–0 GOP sweep. The three-judge panel—composed of two Trump appointees and one Obama appointee—found that the plaintiffs lacked “any direct evidence of racial motivation,” and concluded that “the road to a reliably 9-0 map runs through Memphis. Thus, political motivations readily explain the map’s dilutive effects.”

The April 2026 Louisiana decision, although it struck down a racial gerrymander, paradoxically weakened the Voting Rights Act’s protections for minority voters. In that case, the Court held that the state had impermissibly used race to create a second majority-Black district, and in doing so undermined the very legal foundation that had justified such districts for decades. For states like Tennessee, the new doctrine creates a perverse double bind: a majority-minority district might be unconstitutional if drawn with too much racial consciousness, but its elimination can now be defended as a purely partisan exercise—even when it predictably reduces Black voting power. The Memphis district’s fate is a case study in this legal whipsaw.