United States v. Sheffield Bd. of Comm'rs

1978-03-06

Headline: Voting Rights Act preclearance applies to Alabama cities that never registered voters, and the Court reversed, ruling federal approval was not given for Sheffield’s at‑large council change so local changes need clearance.

Holding: The Court held that Section 5 of the Voting Rights Act covers cities that never conducted voter registration and that the Attorney General’s failure to object to holding a referendum did not constitute approval of the at‑large council election.

Real World Impact:

Cities in covered States must seek federal preclearance for voting changes.
Attorney General inaction on a referendum does not approve specific voting changes.
Local governments must submit full details before seeking DOJ approval.

Topics: voting rights, preclearance, local government elections, civil rights

Summary

Background

The United States sued the City of Sheffield, Alabama, after Sheffield voters approved a May 13, 1975 referendum to change from a commission form to a mayor‑council form of government. Sheffield had never conducted voter registration. City officials notified the Attorney General on March 20, 1975 about the planned referendum. The Attorney General said he would not object to holding the referendum but warned the actual change would require Section 5 preclearance. Sheffield later submitted maps, race and population data, and other details, completing its submission on May 5, 1976. On July 6, 1976 the Attorney General objected to the proposed at‑large method for electing councilmen, and the United States filed suit on August 9, 1976 to enforce that objection.

Reasoning

The Court considered whether Section 5 of the Voting Rights Act covers a city that never registered voters and whether the Attorney General’s failure to object to holding a referendum amounted to approval of the substantive change. The majority concluded Section 5 applies to all entities that control any part of the electoral process within a designated State. It relied on the Act’s text and structure, prior decisions, the Attorney General’s longstanding administrative interpretation, and the legislative history. The Court held Sheffield was covered by §5 and that the Attorney General had not cleared the at‑large councilmanic change.

Real world impact

The decision requires cities inside covered States to obtain federal preclearance for voting changes that might affect racial voting power. Federal approval must address the specific change; permission to hold a referendum alone does not automatically clear detailed voting procedures. The ruling prevents local circumvention of the Act’s protections.

Dissents or concurrances

Justice Stevens, joined by Chief Justice Burger and Justice Rehnquist, dissented, arguing the statutory definition of "political subdivision" limits coverage to counties or units that register voters and warning of administrative burdens; Justices Blackmun and Powell concurred in the judgment.