Rogers v. Lodge

The ruling established that at-large voting systems could be struck down as unconstitutional in cases where there is sufficient evidence to prove that the system was maintained for purposefully discriminatory purposes. Historical data showing that minorities have been denied effective participation in the electoral process, can be employed as evidence in such cases.

Burke County, a large rural county in eastern Georgia, employed an at-large system for electing candidates to its governing body, the county board of commissioners. Under this arrangement, each of the five commissioners were elected by all registered voters in the county, rather than by discrete districts drawn along geographical lines. Although Burke County had a substantial African American population, no minority candidate had ever been elected to its board of commissioners. In 1976, a group of eight African American citizens filed a class action suit in federal district court, on the grounds that the at-large system violated their rights under the First, Thirteenth, Fourteenth, and Fifteenth Amendments to the U.S. Constitution. Rogers further alleged that the dilution of their voting power was intentional and discriminatory on the basis of race.