Rogers v. Lodge 458 U.S. 613 (1982)
ROGERS v. LODGE 458 U.S. 613 (1982)
Rogers v. Lodge involved a successful challenge to an at-large electoral scheme for county commissioners in Burke County, Georgia. The Supreme Court noted that at-large systems are not unconstitutional per se and that a challenge could succeed only upon a showing that the system was established or maintained for a discriminatory purpose. All sides conceded that blacks in Burke County had free access to registration, voting, and candidacy for office. The issue was not, therefore, equal participation in the electoral process but "effective" participation. The Court held that where there was evidence of the lingering effects of past racial discrimination that had limited "the ability of blacks to participate effectively in the political process," the district court was justified in finding that an electoral scheme that did not hold at least the potential of electing minority members to office in proportion to their numbers was maintained for discriminatory purposes in violation of the equal protection clause. Thus the Court, while not requiring proportional representation, nevertheless permitted it to be used as the test in determining whether an electoral system worked to "diminish or dilute the political efficacy" of minorities.
Edward J. Erler
(1986)