In its recent decision in Allen v. Milligan, the Supreme Court, to the evident surprise and pleasure of progressive commentators, handed down a five-to-four provision that sustained a racial-discrimination challenge brought by black voters in Alabama to a district map prepared by Alabama’s Republican Party. That map gave black voters, who compose about 27 percent of Alabama’s population, only one seat in Congress out of the seven seats available for Alabama. By contrast, the plaintiffs’ plan created two majority-black districts, giving black voters majority control over 29 percent of Alabama’s delegation.