Rogers v. Lodge Case Brief

Why is the case important?

The Appellants, Rogers and seven other black citizens from Burke County, Georgia (Appellants) challenged the constitutionality of an at-large voting scheme that violated the United States Constitution (Constitution) despite the scheme’s racial neutrality.

Facts of the case

Eight black citizens of Burke County, Georgia, challenged the at-large system of elections within the county. Although a substantial number of blacks lived within the county, no minority candidate had ever been elected to the Burke County Board of Commissioners, the chief governing body. To be elected, candidates had to receive a majority of the votes cast in the primary or general election.

Question

Whether the at-large system of elections in Burke County, Georgia violates the Fourteenth Amendment rights of Burke County’s black citizens despite being racially – neutral in its application.

Answer

Justice Byron White (J. White). Yes. The at-large voting scheme, although racially neutral, was maintained for invidious or discriminatory purposes. The judgment of the Court of Appeals is affirmed.

Conclusion

The lower court’s determination was not clearly erroneous. It held that there was sufficient evidence to support a finding that appellee African-American citizens had been invidiously excluded from the political process by the appellant county’s system of elections. The sheer geographic size of the county made it difficult for appellees to get to polling places or to campaign for office. The elections system submerged appellees’ will and thus, denied their access to the system. The requirement that candidates run for specific seats enhanced appellees’ lack of access because it prevented a cohesive political group from concentrating on a single candidate.

  • Case Brief: 1982
  • Appellant: Rogers
  • Appellee: Lodge
  • Decided by: Burger Court

Citation: 458 US 613 (1982)
Argued: Feb 23, 1982
Decided: Jul 1, 1982