Riley v. Kennedy, 553 U.S. 406 (2008)
Primary Holding
A state does not need to obtain fresh preclearance under §5 of the Voting Rights Act to reinstate an election practice that was in effect prior to the invalidation of a subsequently enacted law, as the invalidated law is considered to have never gained "force or effect.
In the case of Riley v. Kennedy, the Supreme Court decided that a state doesn't have to get new approval to bring back an old voting practice if a newer law was thrown out by the courts. This matters because it helps ensure that voting processes can return to normal quickly without unnecessary delays, which can affect how people vote. For consumers, this ruling protects their voting rights by making it easier for states to revert to established practices, ensuring that elections can be conducted fairly and efficiently. This case is relevant if someone finds themselves in a situation where a voting law has changed or been invalidated, as it clarifies that previous practices can be reinstated without red tape.
AI-generated plain-language summary to help you understand this case
In Riley v. Kennedy, the underlying dispute arose from the State of Alabama's adoption of a new election practice, which was subsequently precleared under Section 5 of the Voting Rights Act of 1965. After the election was held under this new law, the Alabama Supreme Court invalidated the law, ruling that it violated a provision of the State's Constitution. This led to the question of whether Alabama needed to obtain fresh preclearance to revert to the previous election practice that had been in place before the invalidated law. The procedural history of the case began when the Governor of Alabama, Bob Riley, appealed a decision from the United States District Court for the Middle District of Alabama. The district court had ruled on the implications of the invalidation of the new election practice and its effect on the requirement for preclearance under the Voting Rights Act. The case ultimately reached the Supreme Court, which had to address the novel question of whether the invalidated law had ever gained "force or effect" for the purposes of preclearance. The relevant background context includes the broader framework of the Voting Rights Act of 1965, which was enacted to combat racial discrimination in voting. The Act established stringent requirements for "covered jurisdictions," which included Alabama, mandating that any changes to voting practices be precleared to ensure they did not abridge the voting rights of racial or language minorities. This case highlighted the complexities involved when a state law is invalidated and the implications for voting practices and federal oversight under the Voting Rights Act.
Whether a State must obtain fresh preclearance under §5 of the Voting Rights Act of 1965 to reinstate an election practice that was in effect prior to the enactment of a law subsequently invalidated by the State’s highest court.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- March 24, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Lance v. Dennis, 546 U.S. 459 (2006)
Consumer WonThe Rooker-Feldman doctrine does not bar federal jurisdiction over cases brought by state-court losers challenging state-court judgments rendered before the federal proceedings commenced.
Purcell v. Gonzalez, 549 U.S. 1 (2006)
Consumer LostThe Supreme Court vacated the order of the Court of Appeals, emphasizing that the election procedures implemented under Proposition 200, which required proof of citizenship and identification for voting, were precleared under the Voting Rights Act and did not necessarily disenfranchise qualified voters.
Lance v. Coffman, 549 U.S. 437 (2007)
Consumer LostFederal courts must ensure they have jurisdiction, including standing, before addressing the merits of a case, which requires a plaintiff to demonstrate injury in fact, causation, and redressability.
League of United Latin American Citizens v. Perry, 548 U.S. 399 (2006)
Consumer LostThe Supreme Court held that claims of partisan gerrymandering are non-justiciable under the Constitution, meaning that federal courts do not have the authority to adjudicate such claims, while also affirming that certain provisions of the Voting Rights Act may still apply to specific districts.