Federal Judge orders Alabama to Create new majority-Black Senate District in Montgomery

August 22, 2025 - U.S. District Judge Anna Manasco (a 2019 Trump appointee) has ordered the state of Alabama to redraw its Senate district map to create a new majority-Black district in the Montgomery area. Manasco found in favor of plaintiffs who claimed that the 2021 redistricting map violates Section 2 of the Voting Rights Act by diluting the voting power of Black residents in and around the capital city.

The ruling blocks Alabama from using its current Senate map in the 2026 elections and mandates the creation of a district where Black voters either comprise a voting-age majority or come "quite close to it" – parallelling the language in the 2023 Eleventh Circuit three judge panel ruling in Alabama's Congressional redistricting case.

In That case the judges unanimously ordered the state to create a new majority "or close to it" Black congressional district. When the State Legislature refused and instead sent the court a map that did not come even close to the court's instructions, the court hired a special master to craft a plan that did. The court ordered plan drew Congressman Barry Moore out of his Second district and wrote half of Mobile County out of Congressman Jerry Carl's district. In the election that followed Moore beat Carl and Shomari Figures (D-Mobile) won election in the court ordered racially gerrymandered Second Congressional District that includes half the Black Belt, Montgomery, Troy, Phenix City, and half of Mobile while stretching from Mississippi to Georgia.

In this case state Senator Will Barfoot (R-Pike Road) is clearly in the cross hairs of the court ruling. To create two majority Black Senate districts the Legislature will have to half Senator Kirk Hatcher's (D-Montgomery) district and then swallow surrounding majority White communities like Hope Hull, Snowden, and Pike Road.

Each Alabama State Senate district is designed to represent roughly 143,716 residents, based on the 2020 U.S. Census data. The goal during redistricting is to keep populations as equal as possible to ensure fair representation.

The 35 districts in the state would have to be drawn from a range of about 136,395 to 150,708. The city of Montgomery only has a population of 195,818 people. All of Montgomery County has a population of just 224,980, so these two majority Black districts will have to include about 52,452 people beyond the boarders of Montgomery County. The problem for the Legislature is that in order to comply with the court order that that 52.452 can't be too White and Republican or that map would fail to comply with the judge's order to create two majority minority districts.

The Legislature could look east and take in Macon and Bullock County. Bullock is mostly Black and has a population of 9,987 people, Macon is also 78.2% Black and has a population of 18,730 people. The problem here is that they are already represented by Senator Billy Beasley – the only White Democrat in the Alabama Senate. Beasley's Senate District 28 with close to a 50:50 Black vs. White district. Taking the two Blackest Counties out of SD28 likely means that a White Republican wins the new SD28 – which would run afoul of the civil rights groups that like to sue the state.

Go west into Lowndes and Dallas counties and you cut the heart our of Senator Robert Stewart's (D-Selma) eight county large SD23. Pulling 50,000 votes out of SD23 would mean that district would have to pick up Autauga County from Sen. Clyde Chambliss; but it is only 20.8% Black so would make either SD23 or Hatcher's Montgomery district much Whiter potentially running afoul of the courts as well.

Probably the most workable option would be to carve up Elmore County. With a population of 90,441 (up from 79,558 in 2010) it is one of the fastest growing counties in the state. If the Legislature divides the City of Montgomery and Montgomery County into two ~equally majority Black districts and then racially gerrymander Elmore County (which is only 20.8% Black) into three different district (kicking the Whitest part out to a neighboring White majority district without going too deeply into Macon, Lowndes, and or Bullock Counties to achieve the desired racially gerrymandered nine Democrat dominated Senate districts that the court (and the professional civil rights groups) desire,

The case stems from a 2021 lawsuit filed by the Alabama State Conference of the NAACP, Greater Birmingham Ministries, and a group of Black voters. Represented by the ACLU, the Legal Defense Fund, and the Southern Poverty Law Center, the plaintiffs argued that the state's Senate map packed Black voters into a single Montgomery district while surgically extracting white voters into neighboring districts. This configuration, they claimed, prevented Black residents from influencing elections beyond their immediate district.

Judge Manasco agreed, writing in her 261-page opinion that the map "dilutes the influence of Black voters" and fails to provide them with an equal opportunity to elect candidates of their choice. She emphasized the presence of "intensely racially polarized voting" in the region and concluded that a second district could be reasonably drawn to reflect Montgomery's demographic realities.

The plaintiffs also challenged Senate districts in Huntsville where the NAACP felt they should have a majority minority district too. Manasco found insufficient evidence to support a Voting Rights Act violation there. The court ruled that the plaintiffs had not demonstrated a "reasonably configured district" in Huntsville where Black voters could form a majority.

This partial victory may keep the state from appealing as appealing the ruling would potentially jeopardize the victory for the state in Huntsville.

Benard Simelton, president of the Alabama NAACP, hailed the ruling as a step toward justice but expressed disappointment that Huntsville was left untouched. "This decision proves that when we challenge injustice, we can make progress," Simelton said. "Alabama must now draw fairer districts in Montgomery, but let's be clear-leaving Huntsville untouched still denies many Black Alabamians their rightful representation".

State Sen. Steve Livingston, the Senate majority leader, offered a measured response, saying the ruling was under review. "At this time, we are pleased with the court's ruling in the Huntsville area and disappointed by the ruling in the Montgomery area," said Livingston. "We will determine next steps after a thorough review of the opinion in the coming days," he said.

Alabama Attorney General Steve Marshall has not yet commented, though the state retains the option to appeal. Given its history of challenging redistricting rulings-including two appeals to the U.S. Supreme Court in the congressional case-another legal battle may be on the horizon.

The Alabama Legislature now faces a critical deadline. If lawmakers fail to produce a compliant map in time for the 2026 elections, the court will impose one. If Marshall appeals he will likely seek an injunction on Judge Manasco's ruling. If the eleventh circuit won't grant the injunction appealing for an emergency injunction from the Supreme Court would be the next step if the Attorney General's office takes it that far.

Failing to get an injunction means that the Alabama Legislature will have to have a special session to produce a new map before qualifying for the 2026 Senate elections begins in early January. This redistricting will affect districts far beyond just Montgomery County and could reshape Senate elections next year.

Any map produced by the Legislature will face serious scrutiny by the plaintiffs and would still have to get approved by Judge Manasco.

The state has argued that the Voting Rights Act of 1965 is obsolete and an unconstitutional burden on the rights of the states. Republicans are cautiously optimistic that the Supreme Court will toss our more elements of the Voting Rights Act when it considers the Louisiana Congressional redistricting in October.

Further guidance from the high Court could influence the state's decision on its legal options here.

(AI contributed to this report.)

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