INSTITUTE FOR POLICY RESEARCH

Louisiana v. Callais: ‘A Lock Without a Key’

Following the Supreme Court decision, Chika Okafor explains how “colorblind” rules will continue to perpetuate inequality

Chika Okafor presents his research on social network discrimination at an IPR colloquium
on May 11.

On April 29, the U.S. Supreme Court narrowed a section of the Voting Rights Act of 1965 meant to protect minorities’ political and voting power. In her dissent, Justice Elena Kagan called the court’s ruling in Louisiana v. Callais the “latest chapter in the majority's now-completed demolition of the Voting Rights Act.”

The decision struck down Louisiana's current congressional map, in which two of six districts were majority-Black, as an “unconstitutional racial gerrymander.” According to the last census, nearly one-third of Louisiana’s population is Black, but the ruling forces the state to revert to a map with only one majority-Black district.

For IPR economist and legal scholar Chika Okafor, the ruling raises a more fundamental question his research seeks to answer.

“Do colorblind rules actually produce fairness?” Okafor asked the audience during his IPR colloquium on May 11.

No, according to Okafor's research on social network discrimination—a concept he originated and demonstrated mathematically.

The Invisible Mechanism

Social network discrimination is a phenomenon in which minorities suffer economic and social disadvantages because their social group is smaller. It occurs because people tend to form connections with others who are like them, a scientific concept known as “homophily.”

While homophily is not unique to race, Okafor pointed to research confirming that race and ethnicity are the strongest drivers of social divide in the United States—more than gender, income, and education.

Okafor asked the audience to imagine a “utopian” workplace where applicants from majority and minority racial groups have identical qualifications and employers are “colorblind,” without any prior history of discrimination.

Like in the real world, jobs in this utopian workplace are filled largely through referrals. Majority group members have a larger social network that generates more connections to employees while those in the minority group have fewer. So, how does this play out when White applicants are in the majority, and Black applicants are in the minority?

Okafor’s model shows that Black applicants receive fewer than 29% of referrals despite making up 33% of the applicant pool. And these social network effects extend beyond referrals: White workers earn more than equally qualified Black workers in the same jobs.

Some in the audience asked whether homophily itself is a form of bias. Bias, Okafor replied, implies actively preferring one group over another. Instead, think of homophily in the model as capturing how basic commonalities might foster an interpersonal connection after, let’s say, a 30-minute conversation. With homophily, once a connection is formed, people don’t care if someone is in the majority or minority group.  What drives the disparity isn't preference for one group over another, he explained, but the basic mechanics of how social ties form.

From the Workplace to the Ballot Box and Beyond

If social network discrimination shapes outcomes in the workplace, its effects extend far beyond it—to any arena where opportunities depend on personal connections, including higher education and politics. Wherever social ties guide access to opportunities, the same disparity can emerge, even in systems that aim to be fair.

For minority groups, that can mean fewer referrals, fewer connections, and fewer chances to advance—from admissions and hiring to leadership and representation. In politics, Okafor said, those disadvantages don’t just add up—they compound at every stage of the process.

It starts before a candidate even declares they are running. Okafor said that research shows that a candidate’s connections to party leaders and power brokers, or “gatekeepers,” are critical to their viability. But, in part because of social network discrimination, minorities are recruited less often.

The effects of a smaller network compound across their political trajectory, Okafor pointed out: If they do run, they have a harder time fundraising. If they raise the money, mobilizing voters is harder, as volunteers tend to contact people they know. And if they win, building effective coalitions in office remains an obstacle.

Majority-minority districts, where one or more racial or minority groups hold a majority, become a tool to counteract that compounding disadvantage directly, Okafor explained. Drawn to prevent the dilution of minority votes, such districts ensure these communities have a fairer chance to elect the candidates of their choice by preventing network fragmentation. The Callais ruling, he said, dramatically narrows the ability to create them.

The consequences, Justice Kagan warned in her dissent, will be far-reaching. Majority-minority districts now “exist only on sufferance, and probably not for long,” she wrote. Minority representation in government, she predicts, will sharply decline.

Even before the decision was handed down, voting rights groups projected that a ruling striking down Section 2 could put significant minority representation at risk. If Republican-controlled state legislatures were to redraw their congressional maps without Section 2's protections, analysts estimated that up to 30% of Congressional Black Caucus members and roughly 11% of Congressional Hispanic Caucus members could lose their seats.

The Rucho Trap

In 2019, the Supreme Court ruled in Rucho v. Common Cause that partisan gerrymandering claims are unreviewable by federal courts, meaning states can draw maps to favor one political party without federal courts having any say.

Callais doubled down on that logic, but added a new requirement, creating a legal trap, or a “lock without a key,” as Okafor sees it.

Plaintiffs challenging a redistricting map on racial grounds must now provide evidence of intentional discrimination and “disentangle race from politics,” according to the majority opinion in Callais. That’s often not possible, Okafor said.

“Given the history and the context, the legacy of racial interactions, racial tensions, and racial conflict in the country,” he continued, “It's very difficult, impossible in practice, to actually separate race from politics.”  Significantly, his research on social network discrimination suggests that race itself can actually generate partisan patterns.

The trap gets worse over time: Racial inequality can drive stronger partisan patterns, giving states a built‑in defense. They can point to politics to justify their maps, without addressing the role race may have played in creating those patterns in the first place.

For Okafor, the path forward isn’t yet clear.

“I don't think the near-term answer lies within future voting rights cases,” he said, “and what comes next may require fundamental institutional reforms outside of any courtroom.”

In claiming to remove race-based discrimination, Okafor said, the court has “eased the way for discrimination by another name.”

Chika Okafor is assistant professor of law and an IPR fellow.

Photo credit: Lily Schaffer

Published: May 26, 2026.