Bartlett v. Strickland, 556 U.S. 1 (2009), is a United States Supreme Court case in which a plurality of the Court held that a minority group must constitute a numerical majority of the voting-age population in an area before section 2 of the Voting Rights Act requires the creation of a legislative district to prevent dilution of that group's votes.

Justice Thomas argued that Section 2 does not protect against vote dilution, a position that he still holds as of 2023.

Souter expressed concern that the majority's holding could lead to promoting racial blocs in order to create a minority-majority district when such a situation could be remedied by creating a crossover district.

Justice Ginsburg called on Congress to amend Section 2 to supersede this ruling.

Justice Breyer wrote that a flat 50% rule is impractical because no voting groups are 100% cohesive.