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Shelby County v. Holder

Citation. 570 U.S. __, 133 S.Ct. 2612, 186 L.Ed.2d 651 (2013).

Brief Fact Summary.

Plaintiff sued in federal court, arguing two sections of the Voting Rights Act were unconstitutional.

Synopsis of Rule of Law.

The Constitution is the supreme law of the law and state legislation may not contravene federal laws. The 15th Amendment commands that the right to vote shall not be denied or abridge on the basis of race or color. Congress has the power to enforce.

Facts.

Congress enacted the Voting Rights Act of 1965, which required some states (based on a coverage formula) to obtain federal permission before enacting any laws related to voting. The Act was enacted to address racial discrimination in voting. The provisions at issue were only to be effective for the first five years. Congress, however, continued to authorize them. After their voting changes were denied, Plaintiff sued the Defendant in federal court, arguing the Act was unconstitutional.

Issue.

Whether the coverage formula from the Voting Rights Act of 1965 is still constitutional today.

Held.

No. The coverage formula from the Voting Rights Act of 1965 is not still constitutional today.

Dissent.

Justice Ginsburg

Congress decided the section at issue should remain in effect in order to continue completion of the impressive gains and to prevent backsliding. Those assessments were well within Congress’ province to make. Such judgements regarding enforcement of the 14th and 15th Amendments, as related to voting, warrant substantial deference.

Discussion.

The current burdens of a statute must be justified by the current needs. Any disparate geographic coverage must be sufficiently related to the problem at issue. Applied here, 40-year-old facts have no logical relation to present day. Congress may of course draft another formula based on current conditions. Our country has changed, and while any racial discrimination in voting is too much, Congress must ensure that the legislation it passes to remedy that problem speaks to current conditions. Judgement reversed.


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