City of Rome v. United States case brief

City of Rome v. United States (1980)

Facts: Under Voting Rights Act pre-clearance re: electoral changes granted only if the jurisdiction proves the absence of discriminatory intent and discriminatory effect. Rome convinced DC that certain changes had not been discriminatorily motivated. Court denied pre-clearance b/c the changes would have a discriminatory impact.

Appellants claim: §1 of 15^th A. prohibits only purposeful racial discrimination with regards to voting and that under §2, Congress cannot prohibit voting practices that have a discriminatory effect but no intent.

Holding: Court said that even if §1 prohibits only purposeful discrimination, the prior decisions foreclose any argument that Congress may not outlaw voting practices discriminatory in effect pursuant to §2. Thus, the VRA’s ban on electoral changes that are discriminatory in effect is an appropriate method of promoting the purposes of the 15^th Amendment, even if it is assumed that §1 of the 15^th Amendment only covers intent, and not purpose. Court suggested here that Congress had the authority under §2 of the 15^th Amendment to interpret the meaning of the 15^th Amendment. The only time Congress can affirmatively anticipate a specific past violation is when there is a judicially determined problem.