Holmes v. Moore

Summary

The court affirmed the permanent injunction against S.B. 824, holding that the statute violated the state constitutional guarantee of equal protection because it was enacted with discriminatory intent targeting African-American voters. Applying the Arlington Heights framework, the court held that competent evidence supported the trial court’s findings concerning disparate impact, historical background, the sequence of enactment, and legislative history, and that defendants failed to show the law would have been enacted absent that discriminatory purpose.