Summary of City of Rome (GA) v. United States (1980)
Relevant Facts: The Voting Rights Act of 1965 requires covered jurisdictions to submit electoral changes made after November 1964 for preclearance either to the Department of Justice or to the federal District Court for the District of Columbia. Under the Act, preclearance is granted only if the jurisdiction proves the absence of both discriminatory intent and effect. (Rome’s
The city, in efforts to change the manner in which it elected city officials, persuaded the District Court that a variety of electoral changes had not been discriminatorily motivated. DOJ rejected Rome’s changes not b/c of its discriminatory nature, but the process in which black officials could be elected would be discriminatory in effect.
Issue: Under constitutional law, may the Court uphold Congressional legislation which blocks a city’s electoral process when the process is not discriminatory on its face?
Holding: Yes. The Act’s ban on electoral changes that are discriminatory in effect is an appropriate method of promoting the purposes of the 15th Amendment, even if it is assumed that section one of the Amendment prohibits only intentional discrimination in voting.
Court’s Rationale/Reasoning: Even though the Court’s Equal Protection Clause jurisprudence teaches that the Clause prohibits only purposeful discrimination, not actions with discriminatory effects, the Court found Congress to have been acting within its Section 2, 15th Amendment powers. The Court said it would defer to the judgment of Congress that because of past “ingenious defiance” of the right of black voters, it might be necessary to focus on discriminatory effects to uphold “the spirit” of the 15th Amendment.
The Court found that under section 2 of the 15th Congress may prohibit practices that in and of themselves do not violate section 1 of the Amendment, so long as the prohibitions attacking racial discrimination in voting are appropriate.
Rule: (15th Amendment, section 1) The right of citizens of the U.S. To vote shall not be denied or abridged by the U.S. or by any State on account of race, color, or previous condition of servitude.
(15th Amendment, section 2) The Congress shall have the power to enforce this article by appropriate legislation.
Important Dicta: Aside from the decision, important info…
Dissenting: Justice Rehnquist, in his dissent, contended that the DOJ’s action was not a valid exercise of Congress’s Section 2 remedial powers.