The decision in Bartlett v. Strickland suggests that in order for a district to effectively provide a remedy for minority voters who lack the opportunity to elect representatives of their choice, it must have a minority population that constitutes at least 50% of the citizen voting age population (CVAP). As a result, one key implication for potential redistricting is that:
In districts with less than 50 percent minority race voting populations, redistricting can combine districts to create a minority opportunity district.
This means that redistricting efforts might focus on combining areas with smaller minority populations to create districts where minorities can have a greater chance of being represented, provided that they meet the threshold set by the Supreme Court. Thus, the legal framework established by this decision would limit the strategies used in redistricting to ensure that minority voting power is adequately represented.