As Juneteenth approaches, the holiday provides an opportunity to reflect not only on the formal end of slavery in the United States, but also on the constitutional and legal developments that followed during Reconstruction and beyond.

Juneteenth commemorates June 19, 1865, the date Union General Gordon Granger arrived in Galveston, Texas, and announced General Order No. 3, informing enslaved individuals that they were free pursuant to the Emancipation Proclamation. Although President Lincoln had issued the Emancipation Proclamation more than two years earlier on January 1, 1863, enforcement depended heavily upon Union military presence in former Confederate states.

The legal developments that followed the Civil War fundamentally reshaped the structure of the United States Constitution. Congress adopted the Thirteenth Amendment abolishing slavery, the Fourteenth Amendment guaranteeing equal protection and due process, and the Fifteenth Amendment prohibiting denial or abridgement of voting rights “on account of race, color, or previous condition of servitude.” U.S. Const. amends. XIII-XV.

The Fifteenth Amendment later became an important constitutional foundation for the Voting Rights Act of 1965 (“VRA”), one of the most consequential civil-rights statutes in American history.

Congress enacted the Voting Rights Act during the Civil Rights Movement to address discriminatory voting practices that had persisted for decades after Reconstruction. Pub. L. No. 89-110, 79 Stat. 437 (1965). The statute prohibited numerous practices that states employed to limit voter participation, including literacy tests, and other discriminatory procedures.

One of the most significant provisions of the statute remains Section 2 of the Voting Rights Act, codified at 52 U.S.C. § 10301. Section 2 prohibits any voting practices or procedures that result in discrimination on the basis of race or color.

Over time, Section 2 became central to litigation involving congressional redistricting.

Every ten years, following the United States Census, states redraw congressional district maps to account for population changes. These maps frequently become the subject of litigation because district boundaries can affect representation in Congress and the ability to participate in the political process.

The Supreme Court established the modern framework for many Section 2 redistricting claims in Thornburg v. Gingles, 478 U.S. 30 (1986). There, the Court outlined factors used to evaluate whether minority voters possess an equal opportunity “to participate in the political process and to elect representatives of their choice.” Id. at 44.

At the same time, the Supreme Court has also addressed constitutional limitations on the use of race in districting decisions.

In Shaw v. Reno, 509 U.S. 630 (1993), the Court held that congressional districts drawn predominantly on the basis of race may, under certain circumstances, violate the Equal Protection Clause of the Fourteenth Amendment. The Court later expanded upon those principles in Miller v. Johnson, 515 U.S. 900 (1995), and Cooper v. Harris, 581 U.S. 285 (2017).

The Court’s recent decisions continue to develop this area of law.

In Allen v. Milligan, 599 U.S. 1 (2023), the Supreme Court considered whether Alabama’s congressional map violated Section 2 of the Voting Rights Act by diluting Black voting strength. Chief Justice Roberts, writing for the Court, concluded that the plaintiffs had established a likelihood of success under the framework articulated in Gingles. The Court affirmed lower-court rulings requiring Alabama to create an additional district in which Black voters would have an opportunity to elect candidates of their choice.

More recently, in Louisiana v. Callais, No. 24-109 (U.S. Apr. 29, 2026), the Supreme Court addressed issues involving the relationship between states’ compliance with the voting rights act and the constitution’s limit on race-based redistricting. The litigation arose after Louisiana adopted revised congressional maps containing two majority-Black districts following prior Voting Rights Act litigation. Challengers argued that the revised map constituted an unconstitutional racial gerrymander because race allegedly predominated in the district-drawing process.

The Court’s recent rulings reflect the continuing constitutional tension between Section 2 of the Voting Rights Act and Equal Protection Clause limitations concerning race-conscious governmental action.

These decisions also continue a broader line of Supreme Court jurisprudence involving election law and voting rights, including:

1. Shelby County v. Holder, 570 U.S. 529 (2013), which invalidated the Voting Rights Act’s preclearance coverage formula under Sections 4 and 5;
2. Rucho v. Common Cause, 588 U.S. 684 (2019), which held partisan-gerrymandering claims generally present nonjusticiable political questions; and
3. Brnovich v. Democratic National Committee, 594 U.S. 647 (2021), which addressed Section 2 vote-denial claims.

The legal issues addressed in these cases extend beyond election cycles. Congressional districting influences representation in the United States House of Representatives and may affect legislative priorities, infrastructure funding, healthcare policy, agricultural programs, labor issues, and other areas impacting businesses, municipalities, and communities nationwide.

Juneteenth serves as a reminder that many constitutional questions presently before the courts have historical roots extending back to Reconstruction and the post-Civil War amendments. Questions involving representation, equal protection, federal authority, and voting rights have remained central features of American constitutional law for more than 150 years.

At Golan Christie Taglia, we are proud to celebrate Juneteenth and recognize the extraordinary contributions of Black entrepreneurs, professionals, and business leaders throughout Chicago and across the country. Black-owned and Black-led businesses continue to play a vital role in innovation, commerce, community development, and economic growth. Their success strengthens industries, creates opportunities, and contributes meaningfully to the broader business community.

The Supreme Court’s modern redistricting decisions continue shaping how constitutional principles concerning representation and voting rights are interpreted and applied in the present day.

Cases and Sources

Allen v. Milligan, 599 U.S. 1 (2023).
Brnovich v. Democratic National Committee, 594 U.S. 647 (2021).
Cooper v. Harris, 581 U.S. 285 (2017).
Louisiana v. Callais, No. 24-109 (U.S. Apr. 29, 2026).
Miller v. Johnson, 515 U.S. 900 (1995).
Rucho v. Common Cause, 588 U.S. 684 (2019).
Shaw v. Reno, 509 U.S. 630 (1993).
Shelby County v. Holder, 570 U.S. 529 (2013).
Thornburg v. Gingles, 478 U.S. 30 (1986).
U.S. Const. amends. XIII-XV.
Voting Rights Act of 1965, Pub. L. No. 89-110, 79 Stat. 437.
52 U.S.C. § 10301.
Allen v. Milligan, 599 U.S. 599 U.S. 1 (2023).
Supreme Court of the United States, Louisiana v. Callais, https://www.supremecourt.gov/opinions/25pdf/24-109_21o3.pdf.