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plaintiffappealdiscriminationregulation
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Allen v. State Bd. of Elections, 393 U.S. 544, 89 S.Ct. 817, 22 L.Ed.2d 1

Facts

The cases stem from amendments to Mississippi's election laws that changed how county supervisors and education superintendents were elected, as well as new regulations affecting independent candidates. The plaintiffs, who were qualified electors and potential candidates, argued that these amendments were subject to the Voting Rights Act's approval requirements. In Virginia, a bulletin modifying voting procedures for illiterate voters was also challenged. The lower courts dismissed the complaints, leading to the appeals.

In No. 25, Fairley v. Patterson, involves a 1966 amendment to s 2870 of the Mississippi Code of 1942. The amendment provides that the board of supervisors of each county may adopt an order providing that board members be elected at large by all qualified electors of the county.

Issue

The main legal issue was whether the amendments to state election laws in Mississippi and Virginia were subject to the approval requirements of Section 5 of the Voting Rights Act of 1965.

The central issue is whether these provisions fall within the prohibition of s 5 that prevents the enforcement of 'any voting qualification or prerequisite to voting, or standard, practice, or procedure with respect to voting' unless the State first complies with one of the section's approval procedures.

Rule

The Voting Rights Act of 1965 requires that any new voting qualifications or procedures enacted by covered states must receive federal approval before they can be enforced, as outlined in Section 5 of the Act.

Under s 5, if a State covered by the Act passes any 'voting qualification or prerequisite to voting, or standard, practice, or procedure with respect to voting different from that in force or effect on November 1, 1964,' no person can be deprived of his right to vote 'for failure to comply with' the new enactment 'unless and until' the State seeks and receives a declaratory judgment in the United States District Court for the District of Columbia that the new enactment 'does not have the purpose and will not have the effect of denying or abridging the right to vote on account of race or color.'

Analysis

The Supreme Court analyzed whether the amendments constituted changes in voting qualifications or procedures that fell under the purview of Section 5. The Court determined that the changes made by the states were indeed subject to the Act's requirements, emphasizing the broad interpretation of voting rights intended by Congress to prevent racial discrimination in voting.

We are convinced that in passing the Voting Rights Act, Congress intended that state enactments such as those involved in the instant cases be subject to the s 5 approval requirements.

Conclusion

The Supreme Court vacated the judgment in the Virginia case and reversed the judgments in the Mississippi cases, remanding them with instructions for further proceedings consistent with the opinion that the amendments required federal approval under the Voting Rights Act.

No. 3 judgment vacated; and Nos. 25, 26 and 36 judgments reversed and all cases remanded with instructions.

Who won?

The plaintiffs prevailed in the case as the Supreme Court ruled that the state amendments were subject to the Voting Rights Act's approval process, thus reinforcing the Act's protections against racial discrimination in voting.

The appellants are qualified electors and potential candidates in the two counties. They sought a declaratory judgment in the United States District Court for the Southern District of Mississippi that the amendment to s 2870 was subject to the provisions of s 5 of the Act and hence could not be enforced until the State complied with the approval requirements of s 5.

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