Northwest Austin Municipal Utility District Number One v. Holder

129 S. Ct. 2504 (2009)

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Northwest Austin Municipal Utility District Number One v. Holder

United States Supreme Court
129 S. Ct. 2504 (2009)

Facts

Northwest Austin Municipal District Number One (the district) (plaintiff) was a small utility district with an elected board. Because the district was located in Texas and its board was elected, it was required to seek preclearance pursuant to § 5 of the Voting Rights Act of 1965 before it could change its election rules. The district sued pursuant to the Voting Rights Act’s § 4 bailout provision, seeking release from the preclearance requirement. In support of its suit, the district argued there was no evidence that voter discrimination had ever occurred in the district. The district court denied the bailout request, reasoning that bailouts are unavailable to political subdivisions that, like the district, do not register their own voters. The district appealed, arguing that the Voting Rights Act does not limit bailouts in this manner and challenging the constitutionality of § 5. The United States Supreme Court declined to reach the constitutional issue and instead addressed the statutory issue.

Rule of Law

Issue

Holding and Reasoning (Roberts, C.J.)

Concurrence/Dissent (Thomas, J.)

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