City of Rome v. United States (1980)
Race-based discrimination with respect to voting has pervaded American history, and the U.S. Congress aggressively attacked this wrong by adopting the Voting Rights Act of 1965. At issue in the City of Rome case was the most controversial provision of the Voting Rights Act, which requires federal Justice Department approval of any change in any voting practice put in place by a locale marked by a history of discrimination if that change has either "the purpose [or]... the effect of denying or abridging the right to vote on account of race or color."
The case grew out of efforts to alter both the electorate and the electoral system of the city of Rome, through the city's annexation of neighboring areas and the adoption of an at-large voting scheme for the selection of city commissioners. (Included in the thirteen contested annexations, for example, were 823 new white voters and only 9 new black voters.) Rome proved in court that it had not pursued these changes with any racially discriminatory purpose, but Justice Department approval was denied nonetheless on the ground that the reforms would have an adverse effect on the ability of African Americans to secure local representation. Confronted with a constitutional challenge to Congress's authority to adopt this effects-based standard, the U.S. Supreme Court sided with the Justice Department and blocked Rome's proposed actions.
In recognizing Congress's power under the Fifteenth Amendment of the U.S. Constitution to attack the racially discriminatory effects of voting changes, even in the absence of a current racially discriminatory purpose, the Court both sustained and illustrated the power of the most far-reaching feature of modern federal voting-rights legislation.