As a federal three-judge panel weighs whether Florida’s Senate District 16 was drawn with race as the predominant factor without sufficient justification, what’s at stake reaches far beyond Tampa and St. Petersburg.
The case, Nord Hodges v. Albritton, could shape how racial gerrymandering claims are evaluated in states with similar constitutional provisions.
The plaintiffs, represented by the ACLU of Florida and NYU’s Civil Rights and Racial Justice Clinic, allege that Black voters were intentionally packed into a sprawling district that leaps across Tampa Bay, diminishing their influence in neighboring District 18. If the court agrees, it would mark a rare judicial rebuke under the Equal Protection Clause and Florida’s Fair Districts Amendment.
This trial cuts to the core of redistricting’s political function: who holds power, how it's maintained and who gets to decide. It involves more than competing maps. It’s about whether race was used strategically under the guise of compliance, and what role courts will play in policing those boundaries before the 2026 election cycle begins.
The Legal and Constitutional Backdrop
The legal theory underpinning the challenge to Florida Senate District 16 rests on two intersecting frameworks: the Equal Protection Clause of the Fourteenth Amendment and Article III, Section 21 of the Florida Constitution, known as the Fair Districts Amendment. Both restrict how race can be used in redistricting, though they operate in distinct legal lanes.
Under federal law, race may be considered when necessary to comply with the Voting Rights Act, but it cannot predominate in the drawing of district lines unless narrowly tailored to achieve a compelling interest.
Meanwhile, Florida’s Fair Districts Amendment explicitly prohibits districts drawn with the intent to favor or disfavor a political party or incumbent and requires that districts do not diminish minority voting power. It also mandates contiguity, compactness and adherence to existing political and geographic boundaries.
Burning Bridges
The plaintiffs argue the legislature violated both. According to their claim, District 16 unnecessarily aggregates Black voters from St. Petersburg and East Tampa into a single, geographically fragmented district.
In doing so, the state not only diluted Black voting strength in neighboring District 18 but also constructed a district that lacks shared community interests or contiguity. By linking two dense Black communities across Tampa Bay—without a physical bridge—the plaintiffs contend the legislature packed minority voters in a way that was neither required nor justified by state or federal law.
The Fair Districts language is especially relevant here. Plaintiffs maintain that the state could have drawn a map preserving Black voters' ability to elect candidates of choice without crossing the bay. The state counters that the configuration was necessary to avoid diminishing minority voting strength in Pinellas County, invoking compliance with Tier 1 standards.
That claim, if accepted, would shield the legislature under both constitutional frameworks. If rejected, it would signal that courts are willing to scrutinize legislative motives more aggressively.
Inside the Trial: Strategy, Testimony and Controversy
Over four days in federal court, the trial unfolded as a clash between claims of racial manipulation and assertions of constitutional compliance. The plaintiffs argued that race predominated the creation of Senate District 16, resulting in the unjustified concentration of Black voters from both sides of Tampa Bay into a single district. Their contention is that the legislature could have complied with state and federal requirements without severing community ties or diminishing influence in adjacent District 18.
The defense insisted the map was drawn to satisfy the Tier 1 requirements of Florida’s Fair Districts Amendment. They argued that maintaining Black voters’ ability to elect their candidates of choice required crossing the bay and using recognizable geographic features—like I-275 and the Hillsborough River—to define boundaries. Race, they conceded, was considered, but not improperly prioritized.
Undercutting the plaintiffs’ case was the controversy surrounding ACLU of Florida attorney Nicholas Warren. The defense introduced text messages showing Warren coordinated with Democratic operatives during redistricting and submitted a proposed map without disclosing his affiliation. They alleged Warren’s map became the blueprint for the plaintiffs’ alternative plans, calling the entire case a product of partisan engineering.
A Familiar Pattern
Plaintiffs countered with expert testimony and alternative maps developed by Penn State statistician Cory McCartan, who presented district configurations that preserved Black voting strength without crossing Tampa Bay. Notably absent from the witness stand was former State Sen. Randolph Bracy, whose anticipated testimony was central to the plaintiffs’ narrative but who failed to appear after being subpoenaed.
When communities are divided or artificially stitched together, their ability to organize around shared interests diminishes. The plaintiffs argue this map was designed precisely to neutralize emerging Black political coalitions by packing voters into a district they cannot realistically influence or access.
The broader pattern is familiar. As Black populations grow in suburban and urban centers, legislators have increasingly used strategic line-drawing to contain rather than empower. District 16 serves as a case study in how district lines can be manipulated under the guise of compliance, creating districts that meet numerical thresholds while denying voters functional representation. The court now must decide whether race predominated, and if so, whether it did so unlawfully.
The Politics Behind the Map
Although the lawsuit rests on constitutional claims of racial gerrymandering, the case exposed a deeper political undercurrent: how racial demographics can be shaped to serve partisan objectives. Florida’s redistricting process in the post-2020 cycle, led by a Republican supermajority aligned closely with Governor Ron DeSantis, has drawn national attention for aggressive boundary manipulation.
The controversy echoes Florida’s recent dismantling of the state’s former Fifth Congressional District, a Black-performing district that the legislature replaced with a non-performing version after DeSantis vetoed a compromise map. That move, upheld by the Florida Supreme Court, demonstrated the state’s willingness to sideline both voter-approved reforms and long-standing protections for minority voters.
This convergence of racial and political gerrymandering complicates judicial review. Race predominance remains a justiciable claim; partisan gerrymandering largely does not. But in states like Florida, where race and partisanship closely correlate, the consequences are inseparable. The court’s ruling won’t resolve that tension, but it may signal whether federal courts are still willing to engage it, especially where racial sorting appears designed to blunt collective political agency.
What the Court’s Decision Could Reshape
While the ruling will apply only to this one district, the implications could extend statewide. If the court finds that race impermissibly predominated the redistricting process, it could require a remedial map before the 2026 election cycle and establish a clearer line between permissible consideration of race and unconstitutional racial gerrymandering under both federal and state law.
Because the plaintiffs challenged only District 16, and the court declined to hear claims against District 18 due to insufficient evidence, the coming decision’s immediate scope is narrow. But the reasoning behind the ruling could signal how courts will treat similar challenges under Florida’s Fair Districts Amendment, particularly in regions where racial demographics and political considerations intersect. A decision in favor of the plaintiffs may also prompt preemptive map revisions by lawmakers looking to avoid additional litigation.
Should the court uphold the district, it could embolden legislatures to rely more heavily on justifications rooted in compliance with minority protections, even when maps fracture communities or obscure representational coherence. That would reinforce a deferential standard, effectively narrowing the reach of both federal and state protections unless race is explicitly prioritized and clearly unjustified.
Adding a New Dimension
A ruling striking down District 16 could bolster plaintiffs in other jurisdictions who argue that race has been used strategically to pack or crack minority voters. It could also add weight to claims that state constitutional amendments like Fair Districts are enforceable tools, not just aspirational language.
Florida’s redistricting process has already faced scrutiny over partisan manipulation. This case adds a racial dimension, testing how courts will evaluate the mechanics of racial sorting while suggesting the only reason is compliance.
More broadly, the outcome could influence litigation strategies in states with similar constitutional or statutory language. A strong ruling on the impermissibility of unjustified racial predominance could help clarify how far legislatures can go when balancing compliance with racial fairness provisions against broader principles of contiguity, compactness and community coherence.
A Line in the Sand
The outcome in Nord Hodges v. Albritton will deliver more than a legal resolution—it will signal how courts intend to respond when race and political power collide under modern redistricting regimes. It will also test the durability of constitutional protections in an era where mapmakers have grown increasingly adept at disguising racial sorting as procedural necessity.
Whatever the decision, this case has already forced a rare level of transparency. The trial exposed how racial demographics are weighed, manipulated and defended in the name of compliance. It brought public scrutiny to a process that typically unfolds behind closed doors, with consequences that last a decade or more.
District 16 is just one district. But the ruling will reverberate wherever voters are segmented along racial lines to entrench political outcomes. In that sense, the court’s opinion may not just interpret doctrine. It may shape the boundaries of accountability moving forward.
