The U.S. Supreme Court will once again consider the issue of gerrymandering in Merrill v. Milligan. The litigation centers on the congressional districts drawn along the southern half of Alabama, known as the Black Belt due to its fertile dark soil. [Many of Alabama's African American voters reside in this area, imbuing the region's nickname with a racial connotation, as well.] After the 2020 census, Alabama legislators drew a plan that included only one majority Black district in this region: District 7; the remainder of the Black Belt was fractured among four other districts. No Black candidate has ever won any congressional district in Alabama except in District 7.

Hours after the plan was published, a group of Alabama voters filed three actions challenging the districts. They alleged that the map illegally diluted Black voters in violation of U.S. Constitution and the Voting Rights Act of 1965. After seven days of hearings, a three-judge panel unanimously deemed the plan unlawful under Section 2 of the Voting Rights Act. The 225-page opinion granted the plaintiff-voters' motion for a preliminary injunction and ordered the state to draw a new map before the primary elections in May. In February 2022, the Supreme Court voted 5-4 to stay the injunction pending a full briefing on the merits in October 2022. The controversial decision effectively reinstated the map for the primary and general elections in 2022.