Galveston County’s Commissioners Court has asked a federal court to dismiss remaining claims in the landmark “Petteway” redistricting case as moot, since the county recently adopted a new precinct map.
In 2024, the case produced a ruling that coalition districts are not required under the Voting Rights Act, prompting Texas to redraw its congressional map in 2025—sparking a national power struggle over congressional redistricting.
Background
In 2021, Galveston County decided to redraw its precinct boundaries to reflect shifting populations in light of the most recent census. As a result, the only African American commissioner was drawn out of his precinct.
Despite the commissioner being offered another seat and refusing, a coalition of Democrat plaintiffs sued, hoping to block the 2021 map and revert to the previous boundaries. The case was styled Petteway v. Galveston County, as Terry Petteway—a local officeholder—was lead plaintiff.
Plaintiffs argued, in part, that the new map violated Section 2 of the Voting Rights Act (VRA). Specifically, the suit claimed that coalition districts—where two or more minority groups combine to elect a candidate of choice—must be redrawn forever once they exist.
Galveston County argued before the entire U.S. Fifth Circuit Court of Appeals in New Orleans that coalition districts are nowhere to be found in the VRA, and won. The 2021 maps were allowed to take effect as the case proceeded at the district court level on the remaining constitutional claims, including intentional discrimination and racial gerrymandering.
This decision led commissioner Robin Armstrong—who is also Texas’ RNC committeeman—to petition state legislators to take up congressional redistricting in 2025. He reasoned that Republicans were now at liberty to draw a more aggressive partisan map, since coalition districts were no longer required to be artificially maintained.
A New Map
On June 29, 2026, Galveston County adopted a new precinct map, making the 2021 map outdated.
The following day, county commissioners filed a suggestion of mootness in the U.S. District Court for the Southern District of Texas. They argued that any further litigation of the 2021 map would be futile, since it is no longer in use.
“Here, the challenged 2021 Map has been replaced, there is no remaining controversy over its application, and no declaratory relief or injunction regarding its impact or enforcement can provide any relief,” reads the filing. “In these circumstances, a ruling on the repealed 2021 Map would be an impermissible advisory opinion.”
“The case is now moot, and the Court lacks subject matter jurisdiction and must dismiss,” the filing concluded.
Galveston County’s actions in this case highlight a broader reality in redistricting litigation. The process is often not concluded before a new map is passed, making the case moot.
The district court has yet to rule on the county’s recent filing, but the case is expected to be dismissed.
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