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Constitutional Law Keyed to Choper
Rogers v. Lodge
Citation:
458 U.S. 613 (1982)Facts
Burke County, Georgia is a large, predominantly rural county with a total population of 19,349, of whom 53.6% were Black according to the 1980 census. The county is governed by a five-member Board of Commissioners elected at-large to concurrent four-year terms. Each candidate must run for a specific seat, receive a majority of votes to win, and there are no residency requirements for candidates. Despite Black citizens constituting a majority of the population, they were a minority of registered voters (38%) due to historical discrimination that suppressed Black voter registration. The evidence showed overwhelming bloc voting along racial lines, and no Black person had ever been elected to the Board. The District Court found that past discrimination had restricted Black citizens’ ability to participate in the political process, elected officials had been unresponsive to the needs of the Black community, and the socioeconomic status of Black residents was depressed due to lingering effects of past discrimination. The court also found that the majority vote requirement and numbered post system enhanced the dilutive effect of the at-large system.
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