Federal Court Preliminarily Enjoins Texas's 2025 Congressional Map in LULAC v. Abbott; Judge Smith Dissents

On 11/18/25, the filing date stamped on the opinion, a panel of the federal court for the Western District of Texas granted preliminary injunctions against Texas’s 2025 congressional map (see 2025-08-29–texas-governor-signs-hb-4-new-congressional-map). Judge Jeffrey V. Brown wrote the opinion, joined by Judge David C. Guaderrama; Judge Jerry E. Smith dissented. The opinion holds that “the Court PRELIMINARILY ENJOINS the State from using the 2025 Map,” and orders that “the 2026 congressional election in Texas shall proceed under the map that the Texas Legislature enacted in 2021.”

The ground was race. The court wrote that “the Plaintiff Groups are likely to prove at trial that Texas racially gerrymandered the 2025 Map.” That is the court’s likelihood finding on a preliminary record; the words are the court’s. It also wrote that “politics played a role in drawing the 2025 Map” but that the case was “much more than just politics.”

The Supreme Court stayed the injunction on 2025-12-04–supreme-court-reinstates-texas-mid-decade-redistricting-map and summarily reversed in 2026-04-27–supreme-court-summarily-reverses-texas-congressional-map-ruling-abbott-v-lulac; the district court’s docket records the Supreme Court’s certified judgment.