Edge v. Sumter County School District

Summary

A three-judge federal district court held that Sumter County School District's 1973 shift to at-large board elections was subject to Section 5 of the Voting Rights Act because it resulted from a legislative enactment reflecting elected representatives' policy choices. The court granted plaintiffs summary judgment, enjoined further use of the unprecleared at-large plan, and remanded the case to a single-judge district court to supervise development of a legally enforceable election plan.

Holdings

1. The 1973 change to an at-large method of electing the Sumter County School District Board was subject to Section 5 preclearance because it resulted from the policy choices of the Georgia Legislature, not from a court-directed election plan. The continued use of the system after the Attorney General's objection violated Section 5.
2. The three-judge Section 5 court lacked authority to remedy the malapportionment underlying the invalid election system. After deciding the Section 5 issue, it was required to remand the case to a single-judge district court to supervise development and implementation of a legally enforceable election plan.

Questions Presented

1. Whether the 1973 change from a mixed district and at-large election system to an entirely at-large system was subject to the Section 5 preclearance requirements of the Voting Rights Act.
2. Whether the three-judge Section 5 court could remedy the underlying malapportionment or should remand that issue to a single-judge district court.

Disposition

remanded