Shelby County v. Holder Case Brief

Facts of the case

The Fourteenth Amendment protects every person’s right to due process of law. The Fifteenth Amendment protects citizens from having their right to vote abridged or denied due to race, color, or previous condition of servitude.The Tenth Amendment reserves all rights not granted to the federal government to the individual states. Article Four of the Constitution guarantees the right of self-government for each state.The Voting Rights Act of 1965 was enacted as a response to the nearly century-long history of voting discrimination. Section 5 prohibits eligible districts from enacting changes to their election laws and procedures without gaining official authorization. Section 4(b) defines the eligible districts as ones that had a voting test in place as of November 1, 1964 and less than 50% turnout for the 1964 presidential election. Such districts must prove to the Attorney General or a three-judge panel of a Washington, D.C. district court that the change neither has the purpose nor will have the effectof negatively impacting any individual’s right to vote based on race or minority status. Section 5 was originally enacted for five years, but has been continually renewed since that time.Shelby County, Alabama, filed suit in district court and sought both a declaratory judgment that Section 5 and Section 4(b) are unconstitutional and a permanent injunction against their enforcement. The district court upheld the constitutionality of the Sections and granted summary judgment for the Attorney General. The U.S. Court of Appeals for the District of Columbia Circuit held that Congress did not exceed its powers by reauthorizing Section 5 and that Section 4(b) is still relevant to the issue of voting discrimination.

CONCLUSION

The U.S. Supreme Court found that § 4(b) of the Act was unconstitutional because it was based on a formula that used 40-year-old facts that had no logical relation to the present day, and it held that the formula could not be used as a basis for subjecting jurisdictions to preclearance by federal authorities. Congress could have updated the coverage formula when it extended the Act in 2006 but did not do so, and its failure to act left the Court with no choice but to declare § 4(b) unconstitutional. The Court stated that its decision did not affect the permanent, nationwide ban on racial discrimination in voting that was found in § 2 of the Act, and it issued no ruling on § 5, only on the coverage formula.

  • Advocates: Bert W. Rein for the petitioner Donald B. Verrilli, Jr. Solicitor General, Department of Justice, for the respondents Debo P. Adegbile for the respondents Bobby Pierson, et al.
  • Petitioner: Shelby County, Alabama
  • Respondent: Eric Holder, Jr. Attorney General
  • DECIDED BY:Roberts Court
  • Location: Shelby County, Alabama
Citation: 570 US 529 (2013)
Granted: Nov 9, 2012
Argued: Feb 27, 2013
Decided: Jun 25, 2013
Shelby County v. Holder Case Brief