City of Pleasant Grove v. United States

Background

A small Alabama city called Pleasant Grove, with about 7,000 people and until recently essentially all white, sought approval from the Attorney General to add two nearby parcels of land. One parcel already housed a single extended white family (the Glasgow Addition); the other was vacant land planned for higher-end housing (the Western Addition). At the same time the city refused to annex a neighboring Black area called the Highlands. The Attorney General objected to the proposed annexations, the city sued in federal court in Washington, and a three-judge District Court denied the city declaratory relief.

Reasoning

The central question was whether the annexations were motivated by a racially discriminatory purpose that would violate section 5 of the Voting Rights Act. The Court explained that annexations, including vacant land intended for development, require preclearance and that a covered jurisdiction bears the burden of proving there was no discriminatory purpose or effect. The District Court found the city’s economic explanations to be pretextual and relied on the refusal to annex the Highlands as strong evidence of discriminatory intent. The Supreme Court held those factual findings were not clearly wrong and affirmed the judgment.

Real world impact

The decision means covered cities cannot lawfully use annexation plans to build or preserve racially segregated voting blocks. Covered local governments must justify annexations to show no racial purpose, and objections by the Attorney General or courts can block such annexations. This ruling enforces preclearance rules for even vacant land expected to be developed.

Dissents or concurrances

Justice Powell (joined by the Chief Justice and Justice O’Connor) dissented, arguing the Court improperly relied on speculative future effects and that section 5 should apply only where a change actually alters present voters.