My reasoning may be flawed, but I would think that any state that voted for Obama would not need to use the VRA to create African American majority-minority districts because white racists in the state are obviously outweighed by people willing to vote for a black president.
Perhaps if the US used proportional representation to elect its state legislatures, but obviously not in current circumstances.
Even so, the VRA is about the preferred candidate of minority voters, not minority candidates themselves. No, that is 100% opposite of the underlying facts in the case. The government chose to sanction states where it was perceived that either White voters in Democratic primaries voted in mass to defeat Black candidates, or Blacks were denied an equal opportunity to register and vote as Whites. White candidates were nominated all the time with either the support of a majority of both races, or due solely to leading among Black voters. It was suggested that Blacks being represented by their preferred White candidate was a hollow right, and, therefore, the law ought to grant Black candidates a realistic chance to win in at least some districts.
