Constitutional Law Keyed to Chemerinsky
Rogers v. Lodge
The Burke County Board of Commissioners, a five-member board created in 1911 under state law, governs the county. In order to be elected as a member of the Board, candidates have to receive a majority of the votes in the primary or general election. Although a substantial number of blacks live within the county, no minority candidate had ever been elected as a member. Appellees, eight black citizens of Burke County, Georgia, challenged the county’s at-large system of elections claiming the system diluted the voting power of black citizens. The District Court issued an order in favor of Appellees and required that Burke County be divided into five districts for purposes of electing County Commissioners. The District Court later issued detailed findings of fact and conclusions of law in which it stated that while the present method for electing County Commissioners was “racially neutral when adopted, it is being maintained for invidious purposes.” The Court of Appeals affirmed.
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