How Dr. Robin Armstrong And Harmeet Dhillon Triggered Texas Redistricting

Democrats claim that Trump orchestrated Texas’ mid-decade redistricting, but that narrative is false. The real story centers on Dr. Robin Armstrong, Assistant Attorney General Harmeet Dhillon, and the Petteway case. Texas’ mid-decade redistricting is not a partisan whim but a constitutional necessity. It is the direct result of Petteway v. Galveston County, a case that forced courts, legislators, and the Department of Justice to reckon with the contradiction at the heart of minority coalition districts. For decades, Texas and other states were told they had to create coalition districts where no racial group held a majority but minority groups combined did. That directive, justified under Section 2 of the Voting Rights Act, clashed with the Equal Protection Clause, which forbids race from being a predominant factor in redistricting except when compelled by federal law. Petteway clarified that Section 2 never required coalition districts. If they were never required, then they were never constitutionally permissible. By definition they are unconstitutional racial gerrymanders.

The Galveston case brought the issue into sharp focus. Before 2021, Galveston’s Precinct 3 was drawn as a minority coalition district, represented by Stephen Holmes, a Black Democrat. When the county dismantled that district, scattering Black and Hispanic voters, Holmes was drawn into a heavily white, Republican district. Plaintiffs claimed this violated the VRA. But then the county appointed Dr. Robin Armstrong, a Black Republican, to fill a vacancy in Precinct 4. Armstrong’s presence meant that for the first time the five-member commissioners court had two minority members. Yet the plaintiffs dismissed Armstrong’s appointment as irrelevant, arguing that because he was a Republican, he did not count as black for Voting Rights purposes. That argument infuriated the trial judge and stunned the legal community. It exposed the ideological core of coalition districting: it was never about minority representation in the abstract, it was about electing Democrats.

The Fifth Circuit rightly dismantled the legal scaffolding of this system. It held that Section 2 refers to a “class” of citizens defined by a single racial or ethnic group, not a coalition of groups. The opinion echoed the Sixth Circuit’s ruling in Nixon v. Kent County, which likewise barred coalition claims. Petteway aligned the law with the Constitution, closing a loophole that had permitted race-driven gerrymanders disguised as civil rights.

Dr. Armstrong’s role in the case is significant not only for Galveston but also for national Republican politics. Armstrong has served as the RNC’s National Committeeman for Texas since 2012 and was a close ally of President Trump throughout his first and second terms. He was a Trump campaign surrogate during COVID, frequently appearing in media to defend the administration. Armstrong also publicly backed Harmeet Dhillon in her 2023 campaign for RNC chair. Dhillon, a California attorney and RNC National Committeewoman from 2016 until April 2025, was later appointed by Trump as Assistant Attorney General for the DOJ Civil Rights Division. Armstrong and Dhillon worked closely inside the RNC for nearly a decade and built a strong political relationship. Dhillon was well aware of Armstrong’s role in Petteway, having witnessed his involvement firsthand.

When the Fifth Circuit issued its en banc decision in Petteway, Dhillon, now leading the Civil Rights Division, recognized its sweeping implications. Without Section 2’s protection, coalition districts violated the Constitution. On July 7, 2025, Dhillon sent a letter, co-signed by Deputy AAG Michael Gates, to Governor Greg Abbott and Attorney General Ken Paxton. The letter titled “Unconstitutional Race-Based Congressional Districts (TX-09, TX-18, TX-29, TX-33)” urged Texas to rectify coalition districts in light of Petteway. It cited precedents such as Allen v. Milligan (2023), SFFA v. Harvard (2023), Bartlett v. Strickland (2009), and Thornburg v. Gingles (1986), and threatened legal action under the 14th Amendment if Texas failed to act.

Attorney General Paxton replied with a carefully calibrated response. He agreed that Texas would redraw its districts, but rejected DOJ’s framing that race had been used as a predominant factor in their creation. Paxton stressed that Senator Joan Huffman, chair of the Senate Redistricting Committee, testified that she drew the maps blind to race and aimed to maximize Republican advantage consistent with traditional redistricting principles. This was a legal maneuver to avoid placing Texas back under preclearance. If Paxton admitted the districts were unconstitutional, Texas risked being forced into preclearance, where its maps would require prior federal approval. Instead Paxton told DOJ the state’s maps were legal but moot since they would be redrawn voluntarily.

Predictably, Texas House Democrats claimed that Trump himself had ordered redistricting to protect his agenda in Austin and prevent new impeachment efforts. In reality, every Republican in Texas supported redistricting because it strengthened the party’s position. Trump surely supported it too, given his ties to Armstrong and Dhillon, but the driving force was constitutional law. Once coalition districts were stripped of VRA protection, their existence was itself unconstitutional. States could not maintain them without violating the Equal Protection Clause.

The media prefers to portray mid-decade redistricting as a cynical partisan ploy. They ignore that eliminating coalition districts is not optional. The Fifth Circuit’s ruling makes it mandatory. Without federal law requiring such districts, their existence is racial gerrymandering. The DOJ’s letter was not proof of Trump’s partisan scheming, it was evidence that constitutional limits were being enforced. Yet the media remains silent on Petteway, because to acknowledge it would undermine their narrative.

The implications extend beyond Texas. California, New York, and other states still maintain coalition districts. Once Petteway’s reasoning spreads, they too will face lawsuits. The pending Supreme Court case Louisiana v. Callais could go even further, potentially holding that even majority-minority districts are unconstitutional if race predominated in their creation. That would mark the end of race-based redistricting nationwide.

Texas now faces a choice. The Legislature has proposed dismantling some but not all of its nine coalition districts. That half-measure is inadequate. All nine suffer from the same constitutional defect, all must be eliminated. Doing otherwise is to invite ongoing litigation and to perpetuate a system that was never lawful. The Constitution does not permit selective compliance.

The story of mid-decade redistricting in Texas is the story of constitutional correction. Coalition districts were built on a misreading of the VRA, sustained by partisan interests, and struck down by judicial clarity. Texas Republicans, from Robin Armstrong to Ken Paxton, have recognized the stakes. With the DOJ now under the leadership of Harmeet Dhillon, the federal government has too. The law requires these maps to change, and change they will.

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