Rogers v. Lodge Case Brief
Summary of Rogers v. Lodge, 458 U.S. 613 (1982)
Facts: Burke Cnty is a large rural cnty with a population of 19K, 10K or 35% are Af. American. Whites constitute a maj or the voting age population. Cnty Bd governs the Cnty and is composed of 5 members for 4yr terms, all are white. No Af. American has been elected to the Bd.
Issue(s): Whether the at-large system of elections in Burke Cnty GA dilutes the voting power of Af. Americans and therefore violates the 14th Amend rights of the black citizens of that Cnty?
Holding: An at large election system that is maintained for the purpose of denying Af. Am’s equal access to the political process is UnConst’l.
Procedure: D. Ct. bench trial produced order that Cnty divide into five districts to elect Bd b/c the present method, although initially race neutral, is maintained for invidious purposes. Ct App Affirmed D. Ct application of Mobile. USSCt Affirmed.
Rule(s): 14th and 15th
Rationale: At large voting schemes and multimember districtes tend to minimize the voting strength of minority groups by permitting the political majority to elect All representatives of the district. This process becomes UnConst’l if conceived or operated as a purposeful device to further racial discrimination by minimizing, canceling out or diluting the voting strength of racial elements in the voting population.
Af. Americans have always made up a substantial maj of the population of Cnty, but they are a minority of registered voters. The fact that no Af. Am has been elected is important evidence of purposeful exclusion. But, that fact by itself is not sufficient to prove purposeful discrimination.
The impact of past discrimination, historical discriminatory practices denying Af. Am suffrage, and excluding Af. Am’s from effectively participating provides supporting proof of purposeful exclusion. Hx discrimination is relevant in drawing an inference of purposeful discrimination.
Another factor that is relevant is socio-economic status of Cnty Af. Am.
RELIEF: The sheer geographical size of the Cnty made it more difficult for Af Am’s to get to the polls, which impairs their access to the political process. Cnty has no residency reqmnt, thus all candidates can reside in an all white neighborhood and voting can be concentrated on a single candidate.
Pl’s A: Cnty’s system violates 1st, 13th, 14th, and 15th Amend by diluting the voting power of Af. American citizens.
Df’s A: The D. Ct applied factors outside of Zimmerman its judgment is infirm for the same reasons that led to reversal in Mobile.