City of Rome v. United States

Summary

The Supreme Court upheld the application of the Voting Rights Act's preclearance requirements to electoral changes and annexations made by the City of Rome, Georgia. The Court held that Rome could not independently use the Act's bailout procedure because Georgia was covered as a whole, and that Congress could prohibit voting changes with discriminatory effects under the Fifteenth Amendment. The Court affirmed the judgment of the United States District Court for the District of Columbia.

Holdings

1. A municipality located within a State covered by the Voting Rights Act may not independently obtain bailout from Section 5 coverage under Section 4(a); the bailout procedure is available only to a covered State or to a political subdivision designated as a separate covered unit.
2. When a submitting jurisdiction voluntarily supplements a request for reconsideration with additional information, the 60-day period for the Attorney General's response begins anew upon receipt of the supplemental submission.
3. Section 5 prohibits voting changes that have a discriminatory effect even when they were not adopted with discriminatory purpose.
4. Congress may, under Section 2 of the Fifteenth Amendment, prohibit voting practices that have discriminatory effects, even if the practices do not independently violate Section 1, so long as the prohibition is an appropriate means of enforcing the Amendment.
5. Federalism principles that might otherwise limit congressional regulation of state and local governmental operations do not bar Section 5 of the Voting Rights Act because the Act was enacted under the Civil War Amendments' express enforcement powers.
6. The 1975 seven-year extension of Section 5 was a constitutional method of enforcing the Fifteenth Amendment.
7. The district court did not clearly err in finding that Rome failed to prove that its 1966 electoral changes and 13 disputed annexations would not dilute the effectiveness of Black voters' votes.

Questions Presented

1. Whether the City of Rome could independently obtain bailout from the Voting Rights Act's Section 5 preclearance requirement while Georgia remained a covered State.
2. Whether the Attorney General's response to Rome's request for reconsideration was timely after Rome submitted supplemental information.
3. Whether Section 5 prohibits voting changes having discriminatory effect even absent discriminatory purpose.
4. Whether Congress had authority under Section 2 of the Fifteenth Amendment to prohibit voting changes with discriminatory effects.
5. Whether Section 5's application to state and local voting practices violated federalism principles.
6. Whether the 1975 extension of the Voting Rights Act remained a constitutional exercise of congressional enforcement power.
7. Whether the district court clearly erred in finding that Rome failed to prove that the challenged electoral changes and annexations would not dilute Black voting strength.

Disposition

affirmed