Beer v. United States

Summary

The Court held that Section 5 of the Voting Rights Act did not authorize review of New Orleans's preexisting at-large council seats because the challenged ordinance did not change them. It further held that a reapportionment plan that improves minority voters' relative electoral position does not have a prohibited discriminatory effect under Section 5 unless the new plan independently discriminates on racial grounds in violation of the Constitution. The judgment was vacated and the case remanded for further proceedings, while Justices White and Marshall, joined respectively by Justices Marshall and Brennan, dissented and would have required a broader inquiry into the plan's absolute dilutive effects.