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Historically, the Voting Rights Act has been used to mandate the creation of seats where minorities can choose their Representatives, most noticably in the deep south.
However, with demographics changing, many states are no longer majority or plurality white (For example, California). Does the VRA require these states to draw districts explicitly for white people?
In principle the VRA can apply to any minority group, however there are hurdles to overcome in applying it to a "white" minority. The Gingles test asks if the minority group is sufficiently compact to form a "majority-minority" constituency. The second test is to ask if the minority group is politically cohesive, and the third test is whether the majority is politically cohesive to block the minority's favoured candidate.
Across the states, only Hawaii has a minority identifying as "white alone". In Hawaii it is not clear that the white population of Hawaii is politically cohesive: White voters split 65:35 in favour of Biden in Hawaii, and as Biden won Hawaii, they seem to have little difficulty getting their favoured candidate elected.
If the white vote in Hawaii became significantly different from the Pacific Islander and Asian vote, and if there were enough white voters (and enough electoral districts) that they could reasonably expect to win one or more districts, and if the white voters were geographically compact so that a reasonable district could be formed in which they were a majority, and if the non-white communities were using their majority power to dilute the votes of the white majority (none of these conditions are met) Then there is a case for a VRA act claim to redistrict to form a minority-majority district.
In the Southern States, white voters continue to be a majority. In California "white alone non-Hispanic" now does not form a majority. However when you look at districting this group clearly has been able to elect candidates of their choosing. They are not a politically cohesive group with a dem/rep split and there are already plenty of counties, particularly in the North, in which they are already a minority-majority. So while it would be possible for an illegal redistricting to be done to disenfranchise these voters, it isn't happening, so the VRA hasn't need to be applied.
