Virginia v. United States Et Al.
Headline: Affirmed denial of Virginia’s request to exit Voting Rights Act coverage, leaving federal oversight in place because past handwriting registration rules and school segregation showed discriminatory effects.
Holding: The Court summarily affirmed the lower court’s refusal to exempt Virginia from coverage under the Voting Rights Act, leaving federal oversight in place due to past handwriting registration rules and school segregation effects.
- Keeps Virginia under federal oversight of voting rules.
- Permits federal scrutiny based on past registration and schooling effects.
Summary
Background
The State of Virginia asked a federal court to be exempted from coverage under the Voting Rights Act of 1965. The District Court recognized that Virginia made an initial showing that might support relief, but it found that Virginia’s continued use of a minimal literacy requirement through 1965 had the effect of discriminating on the basis of race. The record shows Virginia’s only literacy requirement was a handwriting registration form, and no literacy test has been used there since 1965.
Reasoning
The key question was whether Virginia should remain subject to ongoing federal oversight under the Act despite its prima facie showing. The lower courts relied on two main grounds: the registration rate for Black citizens in Virginia was about 10% lower than for whites in 1963–1965, and the residual effects of segregated schools. The Supreme Court issued a summary affirmance of the District Court’s denial of Virginia’s request, while a dissenting opinion argued the District Court’s reasons were dubious and that the case deserved full review. The dissent noted a nationwide registration differential of 11.5% in 1966 and pointed out that Virginia might soon escape federal supervision under the Act’s terms.
Real world impact
Because the Court affirmed the lower court’s judgment, Virginia remains subject to the Voting Rights Act’s coverage and its federal oversight for now. The ruling was a summary affirmance rather than a full, detailed opinion, and the dissent urged full consideration, so the issue could be revisited in further proceedings.
Dissents or concurrances
Justice Rehnquist, joined by the Chief Justice and Justice Powell, dissented from the summary affirmance and urged plenary review.
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