Shelby County v. Holder
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| Shelby County v. Holder | |
| Court | U.S. Supreme Court |
|---|---|
| Citation | 570 U.S. 529 (2013) |
| Date decided | June 25, 2013 |
| Appealed from | U.S. Court of Appeals, D.C. Circuit |
| Cited | McCulloch v. Maryland |
| Case Opinions | |
| majority | written by John Roberts joined by Antonin Scalia, Anthony Kennedy, Clarence Thomas, Samuel Alito |
| concurrence | written by Clarence Thomas |
| dissent | written by Ruth Bader Ginsburg joined by Stephen Breyer, Sonia Sotomayor, Elena Kagan |
Facts
The Voting Rights Act of 1965, Section 5 required certain states and local governments to obtain federal preclearance before implementing any changes to their voting laws or practices. Section 4(b) contained the coverage formula that determines which jurisdictions are subjected to preclearance regime based on their histories of discrimination in voting.
Procedural History
Shelby County, Alabama sued U.S. Attorney General Eric H. Holder, Jr. in the U.S. District Court for D.C., which found the Voting Rights Act of 1965 constitutional based on the Enforcement Clause of the 15th Amendment.
Shelby County appealed to the U.S. Court of Appeals for the D.C. Circuit, which affirmed the lower court's decision.Issues
Is Section 4(b) unconstitutional?
Arguments
The coverage formula of Section 4(b) is based on data over 40 years old, making it no longer responsive to current needs and therefore an impermissible burden on the constitutional principles of federalism and equal sovereignty of the states.
Holding
Yes, Section 4(b) is unconstitutional.
Judgment
Reversed.
Comments
RBG dissent: "the Voting Rights Act fully satisfies the standard stated in McCulloch, 4 Wheat., at 421: Congress may choose any means 'appropriate' and 'plainly adapted to' a legitimate constitutional end."
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