Shelby County v. Holder Case Brief Summary | Law Case Explained

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Shelby County v. Holder | 570 U.S. 529 (2013)

In an effort to curtail racial discrimination, Congress passed the Voting Rights Act of 1965. The act put certain states on probation for their historical disenfranchisement of African American voters. In the 2013 case of Shelby County versus Holder, the United States Supreme Court addressed whether these probations are constitutional.

Before Congress’s enactment of the act, several states employed a number of tests required for citizens to pass in order to register to vote. In many states, this resulted in white citizens registering to vote at a rate of approximately 50 percent higher than African American citizens. Congress, fed up with pervasive racial discrimination in voting, enacted the act.

Section Two of the act applies nationwide and bans any standard, practice, or procedure that limits a citizen’s right to vote on account of race or color. For states that previously maintained the most severe voting restrictions, Congress also enacted Section Four and Section Five. Section Four, known as the coverage formula, determines which states would be subject to Section Five. Section Five prohibits changes in state voting procedures without federal approval. The states originally subject to Section Five were Alabama, Georgia, Louisiana, Mississippi, South Carolina, and Virginia.

The coverage formula and Section Five were set to expire in 1970, but Congress reauthorized the act several times, most recently in 2006. At that time, new statistics demonstrated that voter registration was nearly equal between white citizens and African Americans in the states covered by the act, with African American voter turnout exceeding white voter turnout in most of the states identified by the coverage formula.

Armed with this data, Shelby County, located in the covered state of Alabama, sued the United States. Shelby County alleged that Section Four and Five were facially unconstitutional and asked for a permanent injunction against their enforcement. The district court disagreed with Shelby County, finding that the evidence before Congress in 2006 was sufficient to justify reauthorizing Section Four and Five. The United States Court of Appeals for the D.C. Circuit affirmed.

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