Huot v. City of Lowell is certainly not the first time that either the Voting Rights Act (VRA) or the 14^th Amendment have been used to secure equitable voting rights and representation through the court system. There are questions that remain extremely difficult to answer about how voting rights laws are applied to real-life situations. In order to ensure that everyone has fair access to the electoral process, the courts are often asked to rule on similar cases. At-large plurality systems have been addressed in a number of cases, including Rogers v. Lodge, which sought to eliminate the at-large voting system in Georgia. In 1982, the U.S. Supreme Court ruled that the system violated the Equal Protection Clause in the 14^th Amendment. Other elements of the VRA have been addressed in legal battles too, such as in United States v, City of Boston in 2005, which upheld a lower court ruling that the city of Boston must provide voter materials in Spanish to match the demographics of the city’s voters.

Document H

An excerpt from the U.S. Supreme Court Ruling on Rogers v. Lodge, 458 U.S. 613; decided July 1, 1982.

“APPEAL FROM THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

The issue in this case is whether the at-large system of elections in Burke County, Ga., violates the Fourteenth Amendment rights of Burke County's black citizens.

Burke County is a large, predominately rural county located in eastern Georgia… According to the 1980 census, Burke County had a total population of 19,349, of whom 10,385, or 53.6%, were black. The average age of blacks living there is lower than the average age of whites and therefore whites constitute a slight majority of the voting age population. As of 1978, 6,373 persons were registered to vote in Burke County, of whom 38% were black.

The Burke County Board of Commissioners governs the county. It was created in 1911… and consists of five members elected at large to concurrent 4-year terms by all qualified voters in the county… In order to be nominated or elected, a candidate must receive a majority of the votes cast in the primary or general election… No Negro has ever been elected to the Burke County Board of Commissioners.

[Eight] black citizens of Burke County, filed this suit in 1976 in the United States District Court for the Southern District of Georgia. The suit was brought on behalf of all black citizens in Burke County. The complaint alleged that the county's system of at-large elections violates appellees, First, Thirteenth, Fourteenth, and Fifteenth Amendment rights… by diluting the voting power of black citizens… Following a bench trial … the court issued an order on September 29, 1978… ordering that Burke County be divided into five districts for purposes of electing County Commissioners… The present method of electing County Commissioners was… in violation of [the plaintiffs] Fourteenth and Fifteenth Amendment rights.

Document I

An excerpt from the original complaint United States v. City of Boston (July 29, 2005).

“FIRST CAUSE OF ACTION

15. In conducting elections in Boston, Defendants have failed to provide election-related materials, information, and/or assistance in Spanish including, but not limited to, the following:

a) Failing to recruit, appoint, train, and maintain an adequate pool of bilingual poll officials capable of providing effective language election information and assistance to limited English proficient Hispanic citizens; and

b) Failing to translate into Spanish all election-related announcements, instructions, and notices at election sites.…

16. Defendants' failure to provide assistance at all of the polls when such assistance is needed, to recruit, train and assign bilingual poll workers and to translate election information in Spanish and provide adequate bilingual assistance, as described herein, constitutes a violation of Section 203 of the Voting Rights Act…

17. Unless enjoined by this Court, Defendants will continue to violate Section 203 by failing to provide limited English proficient Hispanic citizens of Boston with Spanish-language election information and assistance necessary for their effective political participation.”