In 1982, Calvin Duncan was arrested for murder and was ultimately imprisoned at the Louisiana State Penitentiary for more than 28 years.¹ After prosecutors agreed to reduce Duncan’s sentence to time served, he fought to clear his name. In 2021, this was ultimately successful, a judge vacated his sentence.² In November 2025, he won 68% of the vote to become the Orleans Parish Clerk of Criminal Court, campaigning on criminal justice reform.³ Duncan never got the chance to serve in the position he was elected to, as it was dissolved by a federal court just three hours after his term began.⁴ This targeting of Duncan does not represent something new. Rather, it is indicative of the very same suppression that Black Americans have faced for generations.

Duncan’s position was first threatened by a bill from the Louisiana legislature. Senate Bill 256 would effectively eliminate Duncan’s position by combining “the city’s criminal and civil courts under one clerk of court position”.⁵ The bill advanced to the full Louisiana House,⁶ and Governor Landry committed to signing the bill.⁷ While the governor denied the idea that the bill targeted Duncan,⁸ Duncan had previously faced attacks from government officials. The current Attorney General of Louisiana, Liz Murill, has “insisted Duncan shouldn’t consider himself exonerated”.⁹ Furthermore, Duncan testified at a hearing to lawmakers that when he sought compensation for his wrongful imprisonment, he was threatened by Attorney General Murill with a perjury charge.¹⁰ Ultimately, the government’s efforts were successful as Duncan’s position was eliminated by a federal court hours after he took office.¹¹ Duncan has had his rights challenged by all three branches of the Louisiana government, as well as the federal government.¹² While his story stands out as especially egregious, it follows a familiar pattern of Black disempowerment.

Duncan’s story reflects the shared experience of many African Americans today. He was imprisoned and stripped of any ability to participate in the democratic system.¹³ The Louisiana government then attempted to take his seat away, politically suppressing both him and the majority Black constituency who voted for him.¹⁴ This behavior is not an outlier, but rather an example of the systemic nullification of Black voices. Presently, Kentucky leads the country in disenfranchisement laws, preventing one out of four Black Kentuckians from voting.¹⁵ A 2025 study found that “Black Alabamians were four times more likely to be disenfranchised than whites…”.¹⁶ Particular tactics across states may differ, but they all function to neutralize Black political participation.

As reflected by Duncan’s case, this suppression is also taking place at the federal level. In Louisiana v. Callais, the Supreme Court fundamentally weakened the 1965 Voting Rights Act by ruling that the creation of a second majority-Black district was unconstitutional racial gerrymandering.¹⁷ Relatedly, the Trump Administration-backed SAVE Act would prevent millions of people from voting, disproportionately impacting Black Americans.¹⁸ Notably, the GOP leads current-day efforts to disenfranchise Black voters. Specifically, the GOP uses disenfranchisement as a tool to further their political power, as African Americans overwhelmingly vote for Democratic candidates.¹⁹ Consequently, the GOP is incentivized to reduce the political influence of Black voters. Those Americans are thus denied an integral piece of their identity as citizens.

The struggles Duncan has gone through mirror the overall struggle of Black Americans to have their voices heard. Black Americans are situated against a government apparatus that seeks to constrain their influence, whether it be through disenfranchisement laws, gerrymandering, or the swift elimination of elected positions. The institutions that have targeted Duncan, if left unchanged, will continue to target millions of Black Americans and deny them their place in American society.

^[1] Jack Brook and Sara Cline, Louisiana GOP races to eliminate an elected office won by an exonerated man, The Lufkin Daily News (Apr. 16, 2026), https://lufkindailynews.com/anpa/us/louisiana-gop-races-to-eliminate-an-elected-office-won-by-an-exonerated-man/article_120fa362-f48e-5bec-9a27-a78ae15bb36c.html [https://perma.cc/YL9M-K5MC].

^[2] Id.

^[3] Id.

^[4] Jasmine Franklin, Calvin Duncan disappointed after his role was dissolved, just hours after taking office, WDSU (May 4, 2026), https://www.wdsu.com/article/calvin-duncan-disappointed-after-his-role-was-dissolved-just-hours-after-taking-office/71210156 [https://perma.cc/3QWJ-XPC3].

^[5] Kaylee Poche, Louisiana GOP races to keep an exonerated Black man from taking office in New Orleans, Gambit (Apr. 16, 2026), https://www.nola.com/gambit/news/politics_elections/louisiana-house-panel-passes-new-orleans-clerk-of-court-bill/article_638bacdd-b7c7-45b4-a530-75896f2435a5.html [https://perma.cc/2NKT-7F7K].

^[6] Rae Walberg, Governor champions Orleans Parish Clerk of Court consolidation, Calvin Duncan fights it, WWL (Apr. 17, 2026, 10:18 PM), https://www.wwltv.com/article/news/local/governor-champions-orleans-parish-clerk-of-court-consolidation-calvin-duncan-fights-it-louisiana-new-orleans-politics/289-bcefb8f9-3ce5-44ad-85d4-fb4a7fb786d5 [https://perma.cc/N6R5-PPZL].

^[7] Id.

^[8] Id.

^[9] Greg Larose, Bill to eliminate court clerk post won by Calvin Duncan advances in House – casting shadow over May election, Verite News (Apr. 17, 2026), https://veritenews.org/2026/04/17/calvin-duncan-bill-new-orleans-elections/ [https://perma.cc/6BAK-38KB].

^[10] Id.

^[11] Jasmine Franklin, Calvin Duncan disappointed after his role was dissolved, just hours after taking office, WDSU (May 4, 2026), https://www.wdsu.com/article/calvin-duncan-disappointed-after-his-role-was-dissolved-just-hours-after-taking-office/71210156 [https://perma.cc/3QWJ-XPC3].

^[12] See Brook and Cline, supra note 1 (explaining how Duncan was imprisoned for over 28 years, and attempts from the Louisiana legislature and governor to eliminate Duncan’s position); Franklin, supra note 4.

^[13] Id.

^[14] Id.; United States Census Bureau, https://www.census.gov/quickfacts/fact/table/neworleanscitylouisiana/PST045225 [https://perma.cc/PRH8-XK37].

^[15] Providence Suenge, The Dissolution of Black Kentuckians’ Citizenship Through Disenfranchisement, The Fulcrum (Apr. 16, 2026), https://thefulcrum.us/civic-engagement-education/black-kentucky-voter-disenfranchisement-citizenship-2026 [https://perma.cc/99WL-YQ2P].

^[16] Ralph Chapoco, Study: Alabama’s moral turpitude laws contribute to racial disenfranchisement disparities, Alabama Reflector (Sept. 2, 2025, 7:01 AM), https://alabamareflector.com/2025/09/02/study-black-alabamians-more-likely-to-lose-vote-over-moral-turpitude-than-whites/ [https://perma.cc/NP5N-HNHR].

^[17] What Louisiana v. Callais Means for the Voting Rights Act, Harvard Kennedy School (Apr. 30, 2026), https://www.hks.harvard.edu/faculty-research/policy-topics/fairness-justice/what-louisiana-v-callais-means-voting-rights-act [https://perma.cc/S8QJ-ZMFM].

^[18] Candece Montiel, The SAVE America Act Is A Throwback To Jim Crow Voter Suppression, United National Urban League (Aug. 11, 2026, 10:00 AM), https://nul.org/news/save-america-act-throwback-jim-crow-voter-suppression [https://perma.cc/6QEY-6MKG].

^[19] Pew Research Center, Changing Partisan Coalitions in a Politically Divided Nation (Apr. 9, 2024), https://www.pewresearch.org/politics/2024/04/09/partisanship-by-race-ethnicity-and-education/ [https://perma.cc/8HTU-7L85].