The Voting Rights Act of 1965 triggered profound changes in southern politics, providing the impetus for a revolution in minority voting rights. Despite the passage of the Fifteenth Amendment almost a hundred years before, African-Americans in most southern states could not effectively exercise the right to vote. Congress acted in response to this "long and sorry history" by passing the Voting Rights Act. Section 5, a key provision of the Act, targets particular southern states for federal scrutiny of their electoral practices. In Presley, the Court considered whether seemingly routine administrative decisions that resulted in a dilution of the authority and powers of elected officials were subject to Section 5 scrutiny. This Note explores the recent opinion in light of the background of Section 5, the types of cases to which it has been applied, and the interactions among the different players in the voting rights arena.
Can a Change in Decision-Making Authority Be a Change with Respect to Voting,
57 Mo. L. Rev.
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