## Facts

- Burke County, Georgia used an at-large, countywide system to elect its five-member Board of Commissioners, with concurrent four-year terms.
- The county’s population had long been majority Black, but Black citizens were a minority of registered voters; white citizens constituted a slight majority of the voting population.
- Under the election rules, a candidate had to win a majority in the primary or general election, and voters cast only one vote.
- No Black candidate had ever been elected to the Board of Commissioners.
- The District Court found racially polarized (bloc) voting and that past discrimination had limited Black citizens’ present ability to participate effectively in local politics.
- Black residents brought a class action alleging the at-large system diluted Black voting strength in violation of the Fourteenth and Fifteenth Amendments.
- The District Court found the at-large scheme was neutral in origin but was being maintained for discriminatory purposes and ordered replacement with single-member districts.
- The Fifth Circuit affirmed, and the case reached the Supreme Court on appeal.

## Issues

1. Whether an at-large election system that is neutral in origin violates the Fourteenth and Fifteenth Amendments when maintained for a racially discriminatory purpose that dilutes Black voting strength.
2. Whether the District Court applied the correct requirement of discriminatory purpose for unconstitutional vote dilution.
3. Whether the District Court’s findings of intentional discrimination were clearly erroneous.
4. Whether the order replacing the at-large system with single-member districts was an appropriate remedy.

## Decision

- The Supreme Court affirmed, holding that discriminatory purpose is required for unconstitutional vote dilution under the Fourteenth and Fifteenth Amendments and that the lower courts applied that standard.
- The Court held the District Court’s ultimate finding of intentional discrimination, and the subsidiary factual findings supporting it, were not clearly erroneous.
- The Court accepted that intent may be inferred from circumstantial evidence and the totality of the circumstances, including historical discrimination, racially polarized voting, and persistent exclusion of Black candidates from office.
- The Court upheld the remedial order implementing single-member districts, finding no special circumstances making that remedy inappropriate.

## Legal Principles

- An at-large electoral system may violate the Fourteenth and Fifteenth Amendments when it is maintained for a racially discriminatory purpose that dilutes minority voting strength.
- Proof of discriminatory purpose, not discriminatory effect alone, is required for a constitutional vote-dilution claim under these Amendments.
- Discriminatory intent may be inferred from circumstantial evidence, including historical background, the sequence of events, the impact of the policy, racially polarized voting, and enduring lack of minority electoral success.
- Appellate review of trial-court findings on intent in vote-dilution cases is governed by the clearly erroneous standard; reviewing courts should not reweigh evidence absent clear error.
- Single-member districts are a permissible remedy for unconstitutional vote dilution where the record supports intentional discrimination and no countervailing circumstances counsel against that relief.

## Conclusion

The Court sustained a finding that Burke County’s at-large system, though neutral in origin, was intentionally maintained to dilute Black voting strength, and it affirmed the replacement of that system with single-member districts as a constitutional remedy.


Rogers v. Lodge, 458 U.S. 613 (1982)