City of Rome v. United States Case Brief

Why is the case important?

In 1966 the General Assembly of Georgia changed the electoral process of the City of Rome, Georgia (Appellant). In order for the changes to take effect, the Attorney General of the United States was required to preclear the changes in accordance with the Voting Rights Act of 1966, which he refused to do based on his feeling that it would eliminate the power of the African-American electorate. Appellant then sued for relief.

Facts of the case

Question

Whether the Fifteenth Amendment empowered Congress to impose the rigors of the Voting Rights Act upon the covered jurisdictions?
Whether Congress has the authority to regulate state and local voting through the provisions of the Voting Rights Act?
Whether Congress had the authority to extend the Voting Rights Act for a second seven-year term?

Answer

Yes to all three issues. Affirmed.
The Act’s ban on electoral changes that are discriminatory in effect is an appropriate method of promoting the purposes of the Fifteenth Amendment, even if Section: 1 of the Amendment prohibits only purposeful discrimination, the prior decisions of the Court foreclose any argument that Congress may not, pursuant to Section: 2, outlaw voting practices that are discriminatory in effect. Furthermore, The Court finds that there is no reason to disturb Congress’ considered judgment that banning electoral changes that have a discriminatory impact is an effective method of preventing states from undoing or defeating the rights recently won by African-Americans.
Principles of federalism that might otherwise be an obstacle to congressional authority are overridden by the power to enforce the Civil War Amendments by appropriate legislation. These amendments were designed to expand federal power and intrusion on state sovereignty. Therefore Congress has the authority to regulate state and local voting through the provisions of the Voting Rights Act. The Fifteenth Amendment supersedes contrary exertions of state power, and the act is an appropriate means for carrying out Congress’ constitutional responsibilities.
The seven-year extension of the Voting Rights Act is a constitutional method of enforcing the Fifteenth Amendment.

Conclusion

The United States Supreme Court upheld the decision of the district court. The exemption provided for in 42 U.S.C.S. § 1973b(a) for jurisdictions that could prove that no racial test had been used during the preceding 17 years did not apply to individual municipalities when the entire state was covered under the Voting Rights Act. The city argued that § 1 of the Fifteenth Amendment prohibited only purposeful racial discrimination. The court held that the authority granted by § 2 of the Fifteenth Amendment, which provided for congressional enforcement, was as broad as that granted under the Necessary and Proper Clause. Under that authority, whatever legislation was appropriate to carry out the objects of the Civil War amendments was within the power of Congress.

  • Case Brief: 1980
  • Appellant: City of Rome
  • Appellee: United States
  • Decided by: Burger Court

Citation: 446 US 156 (1980)
Argued: Oct 10, 1979
Decided: Apr 22, 1980