minority, was prohibited. The Voting Rights Act was amended by Congress in the 1980s, Congress to "make states redraw maps if they have a discriminatory effect." In July, 2017, San Juan County, Utah was ordered to redraw its county commission and school board election districts again after U.S. District Judge Robert Shelby ruled them unconstitutional. It was argued that the voice of Native Americans, who were in the majority, had been suppressed "when they are packed into gerrymandered districts." On October 3rd, 2022 the Supreme court heard arguments in Merril v. Milligan to conclude whether or not Alabama is obligated to create a second Black-majority congressional district under the Voting rights Act of 1965. This is because of packing people of color into the 7th district to then separate the rest of the Black electorate into six white-majority states, diluting their ability to impact elections. Affirmative While the Equal Protection Clause, along with Section 2 and Section 5 of the Voting Rights Act, prohibit jurisdictions from gerrymandering electoral districts to dilute the votes of racial groups, the Supreme Court has held that in some instances, the Equal Protection Clause prevents jurisdictions from drawing district lines to favor racial groups. The Supreme Court first recognized these "affirmative racial gerrymandering" claims in Shaw v. Reno (Shaw I) (1993), holding that plaintiffs "may state a claim by alleging that [redistricting] legislation, though race neutral on its face, rationally cannot be understood as anything other than an effort to separate voters into different districts on the basis of race, and that the separation lacks sufficient justification". The Supreme Court reasoned that these claims were cognizable because relying on race in redistricting "reinforces racial stereotypes and threatens to undermine our system of representative democracy by signaling to elected officials that they represent a particular racial group rather than their constituency as a whole". Later opinions characterized the type of unconstitutional harm created by racial gerrymandering as an "expressive harm", which law professors Richard Pildes and Richard Neimi have described as a harm "that results from the idea or attitudes expressed through a governmental action." Subsequent cases further defined the counters of racial gerrymandering claims and how those claims relate to the Voting Rights Act. In United States v. Hays (1995), the Supreme Court held that only those persons who reside in a challenged district may bring a racial gerrymandering claim. In Miller v. Johnson (1995),