OPINION OF THE COURT
RILEY V. KENNEDY
553 U. S. ____ (2008)
SUPREME COURT OF THE UNITED STATES
NO. 07-77
BOB RILEY, GOVERNOR OF ALABAMA, APPELLANT
v. YVONNE KENNEDY et al.
on appeal from the united states district court for
the middle district of alabama
[May 27, 2008]
Justice Ginsburg delivered the
opinion of the Court.
This case presents a novel
question concerning §5 of the Voting Rights Act of 1965. The
setting, in a nutshell: A covered State passed a law adopting a new
election practice, obtained the preclearance required by §5, and
held an election. Soon thereafter, the law under which the election
took place was invalidated by the State’s highest court on the
ground that it violated a controlling provision of the State’s
Constitution. The question presented: Must the State obtain fresh
preclearance in order to reinstate the election practice prevailing
before enactment of the law struck down by the State’s Supreme
Court? We hold that, for §5 purposes, the invalidated law never
gained “force or effect.” Therefore, the State’s reversion to its
prior practice did not rank as a “change” requiring
preclearance.
I
The Voting Rights Act of 1965
(VRA), 79 Stat. 437, as amended, 42 U. S. C. §1973
et
seq., “was designed by Congress to banish the blight of racial
discrimination in voting, which ha[d] infected the electoral
process in parts of our country for nearly a century.”
South
Carolina v.
Katzenbach,
383 U. S. 301, 308
(1966). In three earlier statutes, passed in 1957, 1960, and 1964,
Congress had empowered the Department of Justice (DOJ or
Department) to combat voting discrimination through “case-by-case
litigation.”
Id., at 313. These lawsuits, however, made
little headway. Voting-rights suits were “unusually onerous to
prepare” and the progress of litigation was “exceedingly slow,” in
no small part due to the obstructionist tactics of state officials.
Id., at 314. Moreover, some States “resorted to the
extraordinary stratagem of contriving new rules of various kinds
for the sole purpose of perpetuating voting discrimination in the
face of adverse federal court decrees.”
Id., at 335.
The VRA reflected Congress’
determination that “sterner and more elaborate measures” were
needed to counteract these formidable hindrances.
Id., at
309. Sections 4 and 5 impose the most stringent of the Act’s
remedies. Under §4(b), as amended, a State or political subdivision
is a so-called “covered jurisdiction” if, on one of three specified
coverage dates: (1) it maintained a literacy requirement or other
“test or device” as a prerequisite to voting, and (2) fewer than
50% of its voting-age citizens were registered to vote or voted in
that year’s Presidential election. 42 U. S. C. A.
§1973b(b) (Supp. 2007). Section 4(a) suspends the operation of all
such “test[s] or device[s]” in covered jurisdictions. §1973b(a)
(main ed. and Supp. 2007). Section 5 requires covered jurisdictions
to obtain what has come to be known as “preclearance” from the
District Court for the District of Columbia or the DOJ before
“enact[ing] or seek[ing] to administer” any alteration of their
practices or procedures affecting voting. §1973c(a) (Supp.
2007).
A change will be precleared only if it
“neither has the purpose nor will have the effect of denying or
abridging the right to vote on account of race or color, or
[because of membership in a language minority group].”
Ibid. An election practice has the “effect” of “denying or
abridging the right to vote” if it “lead[s] to a retrogression in
the position of racial [or language] minorities with respect to
their effective exercise of the electoral franchise.”
Beer
v.
United States,
425 U. S. 130, 141
(1976). See also
Young v.
Fordice,
520 U. S. 273, 276
(1997); 28 CFR §51.54 (2007). As amended in 2006, the statute
defines “purpose” to include “any discriminatory purpose.” 120
Stat. 581, codified at 42 U. S. C. A. §1973c(c) (Supp.
2007).
Congress took the extraordinary step of
requiring covered jurisdictions to preclear all changes in their
voting practices because it “feared that the mere suspension of
existing tests [in §4(a)] would not completely solve the problem,
given the history some States had of simply enacting new and
slightly different requirements with the same discriminatory
effect.”
Allen v.
State Bd. of Elections,
393 U. S. 544,
548 (1969). By putting the burden on covered jurisdictions to
demonstrate that future changes would not be discriminatory, §5
served to “shift the advantage of time and inertia from the
perpetrators of the evil to its victims.”
Katzenbach, 383
U. S., at 328.
Sections 4 and 5 were originally scheduled to
lapse once a covered jurisdiction complied with §4(a)’s ban on the
use of tests and devices for five years. See 79 Stat. 438. Finding
continuing discrimination in access to the ballot, however,
Congress renewed and expanded §§4 and 5 on four occasions, most
recently in 2006.[
Footnote 1]
Sections 4 and 5 are now set to expire in 2021, see 42 U.
S. C. A. §1973b(a)(8) (Supp. 2007), but a covered
jurisdiction may “bail out” at any time if it satisfies certain
requirements, see §1973b(a)(1) (main ed. and Supp. 2007).
II
The voting practice at issue in
this litigation is the method used to fill midterm vacancies on the
Mobile County Commission, the governing body of Mobile County,
Alabama. Composed of three members elected by separate districts to
four-year terms, the Commission has the power to levy taxes, make
appropriations, and exercise other county-wide executive and
administrative functions. See Ala. Code §11–3–11 (1975).
We set out first, as pivotal to
our resolution of this case, a full account of two disputes over
the means of filling midterm vacancies on the Commission. The first
occurred between 1985 and 1988; the second began in 2004 and
culminates in the appeal now before us.
A
Alabama is a covered jurisdiction
with a coverage date of November 1, 1964. See 30 Fed. Reg. 9897
(1965). As of that date, Alabama law provided that midterm
vacancies on all county commissions were to be filled by
gubernatorial appointment. See Ala. Code §12–6 (1959). The relevant
provision was later recodified without substantive change as Ala.
Code §11–3–6 (1975), which stated:
“In case of a vacancy, it shall
be filled by appointment by the governor, and the person so
appointed shall hold office for the remainder of the term of the
commissioner in whose place he is appointed.”
In 1985, however, the state legislature passed a
“local law” providing that any vacancy on the Mobile County
Commission occurring “with twelve months or more remaining on the
term of the vacant seat” would be filled by special election rather
than gubernatorial appointment. 1985 Ala. Acts no. 85–237 (1985
Act).[
Footnote 2] The DOJ
precleared this new law in June 1985.
The first midterm opening on the Commission
postpassage of the 1985 Act occurred in 1987, when the seat for
District One—a majority African-American district—became vacant. In
accord with the 1985 Act, the Governor called a special election. A
Mobile County voter, Willie Stokes, promptly filed suit in state
court seeking to enjoin the election. The 1985 Act, he alleged,
violated Art. IV, §105, of the Alabama Constitution, which
provides that no “local law … shall be enacted in any case which is
provided for by a general law.” On Stokes’s reading, the 1985 Act
conflicted with §105 because the Act addressed a matter already
governed by Ala. Code §11–3–6.
The state trial court rejected Stokes’s
argument and entered judgment for the state defendants. Stokes
immediately appealed to the Alabama Supreme Court and sought an
order staying the election pending that court’s decision. The
requested stay was denied and the special election went forward in
June 1987. The winner, Samuel Jones, took office as District One’s
Commissioner in July 1987. Approximately 14 months later, however,
in September 1988, the Alabama Supreme Court reversed the trial
court’s judgment. Finding that the 1985 Act “clearly offend[ed]
§105 of the [Alabama] Constitution,” the court declared the Act
unconstitutional.
Stokes v.
Noonan, 534 So. 2d
237, 238–239 (1988).
The Alabama Supreme Court’s decree cast grave
doubt on the legitimacy of Jones’s election and, consequently, on
his continued tenure in office. The Governor, however, defused any
potential controversy by immediately invoking his authority under
Ala. Code §11–3–6 and appointing Jones to the Commission.
B
The next midterm vacancy on the
Commission did not occur until October 2005, when Jones—who had
been reelected every four years since 1988—was elected mayor of the
city of Mobile. Once again, the method of filling the vacancy
became the subject of litigation. In 2004, the state legislature
had passed (and the DOJ had precleared) an amendment to Ala. Code
§11–3–6 providing that vacancies on county commissions were to be
filled by gubernatorial appointment “[u]nless a local law
authorizes a special election.” 2004 Ala. Acts no. 2004–455 (2004
Act). When the 2005 vacancy arose, three Mobile County voters and
Alabama state legislators—appellees Yvonne Kennedy, James Buskey,
and William Clark (hereinafter Kennedy)—filed suit against
Alabama’s Governor, Bob Riley, in state court. The 2004 Act’s
authorization of local laws providing for special elections, they
urged, had revived the 1985 Act and cured its infirmity under §105
of the Alabama Constitution. Adopting Kennedy’s view, the state
trial court ordered Governor Riley to call a special election.
While the Governor’s appeal to
the Alabama Supreme Court was pending, Mobile County’s election
officials obtained preclearance of procedures for a special
election, scheduled to take place in January 2006. In November
2005, however, the Alabama Supreme Court reversed the trial court’s
order. Holding that the 2004 Act “provide[d] for prospective
application only” and thus did not resurrect the 1985 Act,
Alabama’s highest court ruled that “Governor Riley [wa]s authorized
to fill the vacancy on the Mobile County Commission by
appointment.”
Riley v.
Kennedy, 928 So. 2d
1013, 1017 (2005). Governor Riley promptly exercised that authority
by appointing Juan Chastang.
The day after the Alabama Supreme Court denied
rehearing, Kennedy commenced the instant suit in Federal District
Court. Invoking §5, she sought declaratory relief and an injunction
barring Governor Riley from filling the Commission vacancy by
appointment unless and until Alabama gained preclearance of the
decisions in
Stokes and
Kennedy. As required by
§5, a three-judge District Court convened to hear the suit. See 42
U. S. C. A. §1973c(a) (Supp. 2007);
Allen, 393
U. S., at 563.
In August 2006, the three-judge court, after a
hearing, granted the requested declaration. The court observed
first that for purposes of §5’s preclearance requirement,
“[c]hanges are measured by comparing the new challenged practice
with the baseline practice, that is, the most recent practice that
is both precleared and in force or effect.” 445 F. Supp. 2d
1333, 1336 (MD Ala.). It then determined that the 1985 Act’s
provision requiring special elections had been both precleared and
put into “force or effect” with the special election of Jones in
1987. It followed, the District Court reasoned, that the
gubernatorial appointment called for by
Stokes and
Kennedy ranked as a change from the baseline practice;
consequently “the two [Alabama Supreme Court] decisions … should
have been precleared before they were implemented.” 445
F. Supp. 2d, at 1336
.
Deferring affirmative relief, the District
Court gave the State 90 days to obtain preclearance of
Stokes and
Kennedy. 445 F. Supp 2d, at 1336.
Without conceding that preclearance was required, the State
submitted the decisions to the DOJ. Finding that the State had
failed to prove that the reinstatement of gubernatorial appointment
would not be retrogressive, the Department denied preclearance. See
App. to Motion to Dismiss or Affirm 2a–8a. “The African-American
voters of District 1,” the DOJ explained, “enjoy the opportunity to
elect minority candidates of their choice” under the 1985 Act.
Id., at 6a. A change to gubernatorial appointment would be
retrogressive because it “would transfer this electoral power to a
state official elected by a statewide constituency whose racial
make-up and electoral choices regularly differ from those of the
voters of District 1.”
Ibid.
After the State unsuccessfully sought DOJ
reconsideration, Kennedy returned to the District Court and filed a
motion for further relief. On May 1, 2007, the District Court ruled
that “Governor Bob Riley’s appointment of Juan Chastang to the
Mobile County Commission … was unlawful under federal law” and
vacated the appointment. App. to Juris. Statement 1a–2a. Governor
Riley filed a notice of appeal in the District Court on May 18,
2007, and a Jurisdictional Statement in this Court on July 17,
2007. In November 2007, we postponed a determination of
jurisdiction until our consideration of the case on the merits. 552
U. S. ___.
In the meantime, a special election was held
in Mobile County in October 2007 to fill the vacancy resulting from
the District Court’s order vacating Chastang’s
appointment.[
Footnote 3]
Chastang ran in the election but was defeated by Merceria Ludgood,
who garnered nearly 80% of the vote. See Certification of Results,
Special Election, Mobile County (Oct. 16, 2007),
http://records.mobile-county.net/
ViewImagesPDFAll.Aspx?ID=2007081288 (as visited May 22, 2008, and
available in Clerk of Court’s case file). Ludgood continues to
occupy the District One seat on the Commission. Her term will
expire in November 2008.[
Footnote
4]
III
Before reaching the merits of
Governor Riley’s appeal, we first take up Kennedy’s threshold
objection. The appeal, Kennedy urges, must be dismissed as
untimely.
Section 5 provides that “any
appeal” from the decision of a three-judge district court “shall
lie to the Supreme Court.” 42 U. S. C. §1973c(a). Such an
appeal must be filed within 60 days of the District Court’s entry
of a final judgment. See 28 U. S. C. §2101(b). Kennedy
maintains that Governor Riley’s May 18, 2007 notice of appeal came
too late because the District Court’s August 2006 order qualified
as a final judgment. If Kennedy’s characterization is correct, then
Governor Riley’s time to file an appeal expired in October 2006 and
his appeal must be dismissed. But if, as Governor Riley maintains,
the District Court did not issue a final judgment until the order
vacating Chastang’s appointment on May 1, 2007, then the Governor
filed his appeal well within the required time.
A final judgment is “one which ends the
litigation on the merits and leaves nothing for the court to do but
execute the judgment.”
Catlin v.
United States,
324 U. S. 229,
233 (1945).[
Footnote 5] The
District Court’s August 2006 order declared that the Alabama
Supreme Court’s decisions in
Stokes and
Kennedy
required preclearance, but that order left unresolved Kennedy’s
demand for injunctive relief. We have long held that an order
resolving liability without addressing a plaintiff’s requests for
relief is not final. See
Liberty Mut. Ins. Co. v.
Wetzel,
424
U. S. 737, 742–743 (1976). See also 15B C. Wright, A. Miller,
& E. Cooper, Federal Practice and Procedure §3915.2, p. 271 (2d
ed. 1992).
Resisting the conclusion these authorities
indicate, Kennedy maintains that the August 2006 order ranked as a
final decision for two reasons. First, she contends, that order
conclusively settled the key remedial issue, for it directed
Governor Riley to seek preclearance of the Alabama Supreme Court’s
decisions in
Stokes and
Kennedy. See Brief for
Appellees 26–27. This argument misapprehends the District Court’s
order: Far from requiring the Governor to seek preclearance, the
District Court expressly allowed for the possibility that he would
elect not to do so. See 445 F. Supp. 2d, at 1337 (“Defendant
Riley is to keep the court informed of what action,
if
any, the State decides to take … .” (emphasis added)).
Second, Kennedy notes that the District Court directed entry of its
August 2006 order “as a final judgment pursuant to Rule 58 of the
Federal Rules of Civil Procedure,”
ibid. See Brief for
Appellees 27. “The label used by the District Court,” however,
“cannot control [an] order’s appealability.”
Sullivan v.
Finkelstein,
496 U. S. 617, 628,
n. 7 (1990). See also
Wetzel, 424 U. S., at
741–743.
Because the District Court did not render its
final judgment until May 1, 2007, Governor Riley’s May 18 notice of
appeal was timely. We therefore proceed to the merits.
IV
Prior to 1985, Alabama filled
midterm vacancies on the Mobile County Commission by gubernatorial
appointment. The 1985 Act adopted a different practice—special
elections. That new practice was used in one election only, held in
1987. The next year, the Alabama Supreme Court determined, in
Stokes v.
Noonan, that the Act authorizing
special elections was invalid under the State’s Constitution.
Properly framed, the issue before us is whether §5 required Alabama
to obtain preclearance before reinstating the practice of
gubernatorial appointment in the wake of the decision by its
highest court invalidating the special-election law.[
Footnote 6]
It is undisputed that a “change”
from election to appointment is a change “with respect to voting”
and thus covered by §5. See
Allen, 393 U. S., at 569–570;
Presley v.
Etowah County Comm’n,
502 U. S. 491, 502–503
(1992). We have also stated that the preclearance requirement
encompasses “voting changes mandated by order of a state court.”
Branch v.
Smith,
538 U. S. 254, 262
(2003). See also
Hathorn v.
Lovorn,
457 U. S. 255, 265–266,
and n. 16 (1982). The question is whether, given the
circumstances here presented, any “change” within the meaning of §5
occurred in this case.
In order to determine whether an election
practice constitutes a “change” as that term is defined in our §5
precedents, we compare the practice with the covered jurisdiction’s
“baseline.” We have defined the baseline as the most recent
practice that was both precleared and “in force or effect”—or,
absent any change since the jurisdiction’s coverage date, the
practice that was “in force or effect” on that date. See
Young, 520 U. S., at 282–283. See also
Presley,
502 U. S., at 495. The question is “whether a State has ‘enact[ed]’
or is ‘seek[ing] to administer’ a ‘practice or procedure’ that is
‘different’ enough” from the baseline to qualify as a change.
Young, 520 U. S., at 281 (quoting 42 U. S. C.
§1973c).[
Footnote 7]
For the reasons that follow, we conclude that
the 1985 Act was never “in force or effect” within the meaning of
§5. At all relevant times, therefore, the baseline practice for
filling midterm vacancies on the Commission was the pre-1985
practice of gubernatorial appointment. The State’s reinstatement of
that practice thus did not constitute a change requiring
preclearance.
A
We have directly addressed the §5
term of art “in force or effect” on three prior occasions. As will
become clear, these precedents do not control this case because
they differ in a critical respect. They do, however, provide the
starting point for our inquiry.
In
Perkins v.
Matthews,
400 U. S. 379 (1971),
the question was what practice had been “in force or effect” in the
city of Canton, Mississippi, on that State’s §5 coverage date,
November 1, 1964. A 1962 state law required selection of city
aldermen by at-large elections rather than by ward. Canton,
however, “ignored the mandate [of the statute] in the conduct of
the 1965 municipal elections and, as in 1961, elected aldermen by
wards.”
Id., at 394. In the 1969 election, the city sought
to switch to at-large elections. We held that this move was a
change requiring preclearance because election by ward was “the
procedure
in fact ‘in force or effect’ in Canton on
November 1, 1964.”
Id., at 395.
We endeavored to determine in
Perkins
the voting procedure that would have been followed on the coverage
date, November 1, 1964. Two choices were apparent: the state law on
the books since 1962 calling for at-large elections, or the
practice Canton actually used,
without challenge, in
1965—election by wards. We picked the 1965 practice as the more
likely indicator of the practice Canton would have employed had it
held an election on the coverage date, just seven months earlier.
See
id., at 394–395.
Similarly, in
City of Lockhart v.
United States,
460 U. S. 125 (1983), the question was
what practice had been “in force or effect” in Lockhart, Texas, on
the relevant §5 coverage date, November 1, 1972. For more than 50
years, without challenge, the city had used a “numbered-post”
system to elect its city council. See
id., at 132,
n. 6.[
Footnote 8] A group
of plaintiffs nonetheless contended that the numbered-post system
was never “in force or effect” because it lacked state-law
authorization. We noted that the validity of the numbered-post
system under state law was “not entirely clear.”
Id., at
132.[
Footnote 9] Relying on
Perkins, we considered the uncertain state of Texas law
“irrelevant,” for “[t]he proper comparison [wa]s between the new
system and the system actually in effect on November 1, 1972,
regardless of what state law might have required.” 460 U. S., at
132 (footnote omitted).
Finally, in
Young v.
Fordice, decided in 1997, the question was whether a
provisional voter registration plan implemented by Mississippi
election officials had been “in force or effect.” Believing that
the state legislature was about to amend the relevant law, the
officials had prepared and obtained preclearance for a new voter
registration scheme. See 520 U. S., at 279. Roughly one-third of
the State’s election officials implemented the plan, registering
around 4,000 voters. See
id., at 278, 283. As it turned
out, however, the state legislature failed to pass the amendment,
and the voters who had registered under the provisional plan were
required to reregister. See
id., at 278. When the case
reached us, we rejected the argument that “the [p]rovisional
[p]lan, because it was precleared by the Attorney General, became
part of the baseline against which to judge whether a future change
must be precleared.”
Id., at 282. Regarding the
provisional plan as a “temporary misapplication of state law,” we
held that, for §5 purposes, the plan was “never ‘in force or
effect.’ ”
Ibid. We emphasized that the officials who
implemented the provisional plan “did not intend to administer an
unlawful plan” and that they abandoned it “as soon as its
unlawfulness became apparent.”
Id., at 283. We also noted
that the provisional plan had been used for only 41 days and that
the State “held no elections” during that period.
Ibid.
B
Perkins and
Lockhart established that an election practice may be “in
force or effect” for §5 purposes despite its illegality under state
law if, as a practical matter, it was “actually in effect.”
Lockhart, 460 U. S., at 132. Our more recent decision in
Young, however, qualified that general rule: A practice
best characterized as nothing more than a “temporary misapplication
of state law,” we held, is
not in “force or effect,” even
if actually implemented by state election officials. 520 U. S., at
282.
If the only relevant factors were
the length of time a practice was in use and the extent to which it
was implemented, this would be a close case falling somewhere
between the two poles established by our prior decisions. On one
hand, as in
Young, the 1985 Act was a “temporary
misapplication” of state law: It was on the books for just over
three years and applied as a voting practice only once. In
Lockhart, by contrast, the city had used the numbered-post
system “for over 50 years without challenge.” 460 U. S., at 132,
n. 6. (
Perkins is a less clear case: The city failed
to alter its practice in response to changed state law for roughly
seven years, but only a single election was held during that
period. See 400 U. S., at 394.) On the other hand, in
Young no election occurred during the time the provisional
registration plan was in use, while in this case one election
was held under the later-invalidated 1985 Act.
We are convinced, however, that an
extraordinary circumstance not present in any past case is
operative here, impelling the conclusion that the 1985 Act was
never “in force or effect”: The Act was challenged in state court
at first opportunity, the lone election was held in the shadow of
that legal challenge, and the Act was ultimately invalidated by the
Alabama Supreme Court.
These characteristics plainly distinguish the
present case from
Perkins and
Lockhart. The state
judiciary had no involvement in either of those cases, as the
practices at issue were administered without legal challenge of any
kind. And in
Lockhart, we justified our unwillingness to
incorporate a practice’s legality under state law into the §5
“force or effect” inquiry in part on this ground: “We doubt[ed]
that Congress intended” to require “the Attorney General and the
District Court for the District of Columbia” to engage in
“speculation as to state law.” 460 U. S., at 133, n. 8. Here,
in contrast, the 1985 Act’s invalidity under the Alabama
Constitution has been definitively established by the Alabama
Supreme Court.
The prompt legal challenge and the Alabama
Supreme Court’s decision not only distinguish this case from
Perkins and
Lockhart; they also provide strong
cause to conclude that, in the context of §5, the 1985 Act was
never “in force or effect.” A State’s highest court is
unquestionably “the ultimate exposito[r] of state law.”
Mullaney v.
Wilbur,
421 U. S. 684, 691
(1975). And because the prerogative of the Alabama Supreme Court to
say what Alabama law is merits respect in federal forums,[
Footnote 10] a law challenged at
first opportunity and invalidated by Alabama’s highest court is
properly regarded as null and void
ab initio, incapable of
effecting any change in Alabama law or establishing a voting
practice for §5 purposes. Indeed, Kennedy and the United States
appear to concede that the 1985 Act would not have been “in force
or effect” had the Alabama Supreme Court stayed the 1987 election
pending its decision in
Stokes (or simply issued its
decision sooner). See Brief for Appellees 51; Brief for United
States as
Amicus Curiae 23–24.
There is no good reason to hold otherwise
simply because Alabama’s highest court, proceeding at a pace hardly
uncommon in litigated controversies, did not render its decision
until after an election was held. In this regard, we have
recognized that practical considerations sometimes require courts
to allow elections to proceed despite pending legal challenges. Cf.
Purcell v.
Gonzalez,
549 U. S. 1, 5–6 (2006)
(per curiam) (“Given the imminence of the election and the
inadequate time to resolve the factual disputes, our action today
shall of necessity allow the election to proceed without an
injunction suspending the [challenged] rules.”).
Ruling as Kennedy and the United States urge,
moreover, would have the anomalous effect of binding Alabama to an
unconstitutional practice because of a state trial court’s error.
If the trial court had gotten the law of Alabama right, all agree,
there would have been no special election and no tenable argument
that the 1985 Act had ever gained “force or effect.” But the trial
court misconstrued the State’s law and, due to that court’s error,
an election took place. That sequence of events, the District Court
held, made the Act part of Alabama’s §5 baseline. No precedent of
this Court calls for such a holding.
The District Court took care to note that its
decision “d[id] not in any way undermine
[Stokes and
Kennedy] under state law.” 445 F. Supp. 2d, at 1337.
In some theoretical sense, that may be true. Practically, however,
the District Court’s decision gave controlling effect to the
erroneous trial court decision and rendered the Alabama Supreme
Court’s corrections inoperative. Alabama’s Constitution, that
State’s Supreme Court determined, required that, in the years here
involved, vacancies on the Mobile County Commission be filled by
appointment rather than special election. Nothing inherent in the
practice of appointment violates the Fifteenth Amendment or the
VRA. The DOJ, however, found that a
change from special
elections to appointment had occurred in District One, and further
found that the change was retrogressive, hence barred by §5. The
District Court’s final decision, tied to the DOJ determination,
thus effectively precluded the State from reinstating gubernatorial
appointment, the only practice consistent with the Alabama
Constitution pre-2006.[
Footnote
11] Indeed, Kennedy’s counsel forthrightly acknowledged that
the position she defends would “loc[k] into place” an
unconstitutional practice. Tr. of Oral Arg. 32.
The dissent, too, appears to concede that its
reading of §5 would bind Alabama to an unconstitutional practice
because of an error by the state trial court. See
post, at
7. But it contends that this imposition is no more “offensive to
state sovereignty” than “effectively requiring a State to
administer a law it has repealed,”
post, at 8—a routine
consequence of §5. The result described by the dissent, however,
follows directly from the Constitution’s instruction that a state
law may not be enforced if it conflicts with federal law. See Art.
VI, cl. 2. Section 5 prohibits States from making retrogressive
changes to their voting practices, and thus renders any such
changes unenforceable. To be sure, this result constrains States’
legislative freedom. But the rule advocated by the dissent would
effectively preclude Alabama’s highest court from applying to a
state law a provision of the State Constitution entirely harmonious
with federal law. That sort of interference with a state supreme
court’s ability to determine the content of state law, we think it
plain, is a burden of a different order.
This burden is more than a hypothetical
concern. The realities of election litigation are such that lower
state courts often allow elections to proceed based on erroneous
interpretations of state law later corrected on appeal. See,
e.g., Akins v.
Secretary of State, 154
N. H. 67, 67–68, 74, 904 A. 2d 702, 703, 708 (2006)
(preelection challenge rejected by a state trial court but
eventually sustained in a postelection decision by the State
Supreme Court);
Cobb v.
State Canvassing Bd.,
2006–NMSC–034, ¶¶1–17, 140 N. M. 77, 79–83 (2006) (same);
Maryland Green Party v.
Maryland Bd. of
Elections, 377 Md. 127, 137–139, 832 A. 2d 214, 220–221
(2003) (same);
O’Callaghan v.
State, 914
P. 2d 1250, 1263–1264 (Alaska 1996) (same);
Peloza v.
Freas, 871 P. 2d 687, 688, 692 (Alaska 1994) (same).
We decline to adopt a rigid interpretation of “in force or effect”
that would deny state supreme courts the opportunity to correct
similar errors in the future.
C
Although our reasoning and the
particular facts of this case should make the narrow scope of our
holding apparent, we conclude with some cautionary observations.
First, the presence of a judgment by Alabama’s highest court
declaring the 1985 Act invalid under the State Constitution is
critical to our decision.[
Footnote 12] We do not suggest the outcome would be the
same if a potentially unlawful practice had simply been abandoned
by state officials after initial use in an election. Cf.
Perkins, 400 U. S., at 395. Second, the 1985 Act was
challenged the first time it was invoked and struck down shortly
thereafter. The same result would not necessarily follow if a
practice were invalidated only after enforcement without challenge
in several previous elections. Cf.
Young, 520 U. S., at
283 (“[T]he simple fact that a voting practice is unlawful under
state law does not show, entirely by itself, that the practice was
never ‘in force or effect.’ … A State, after all, might
maintain in effect for many years a plan that technically …
violated some provision of state law.”). Finally, the consequence
of the Alabama Supreme Court’s decision in
Stokes was to
reinstate a practice—gubernatorial appointment—identical to the
State’s §5 baseline. Preclearance might well have been required had
the court instead ordered the State to adopt a novel
practice.[
Footnote 13]
* * *
For the reasons stated, the
judgment of the United States District Court for the Middle
District of Alabama is reversed, and the case is remanded for
further proceedings consistent with this opinion.
It is so ordered.
Footnote 1
See Fannie Lou Hamer, Rosa Parks, and Coretta
Scott King Voting Rights Act Reauthorization and Amendments Act of
2006, 120 Stat. 577; Voting Rights Act Amendments of 1982, 96 Stat.
131; Voting Rights Act Amendments of 1975, 89 Stat. 400; Voting
Rights Act Amendments of 1970, 84 Stat. 314.
Footnote 2
Under the Alabama Constitution, a “general”
law is “a law which in its terms and effect applies either to the
whole state, or to one or more municipalities of the state less
than the whole in a class.” Art. IV, §110. A “special or
private” law is a law that “applies to an individual, association
or corporation.”
Ibid. A “local” law is “a law which is
not a general law or a special or private law.”
Ibid. The
1985 Act was a local law because it applied only to Mobile County;
the remainder of the State continued to be governed by Ala. Code
§11–3–6 (1975).
Footnote 3
The District Court denied the Governor’s
motion to stay its judgment pending this appeal. See App. 7.
Footnote 4
Regardless of the outcome of this litigation,
the method for filling future midterm vacancies on the Commission
appears to have been settled. In 2006, the Alabama Legislature
enacted a new measure providing that, on a going-forward basis,
vacancies on the Commission will be filled by special election. See
2006 Ala. Acts no. 2006–342. The DOJ precleared the statute in July
2007. The passage of this law does not render this case moot: If
the Governor prevails in his appeal, Chastang may seek
reinstatement to the Commission to serve out the remainder of the
term ending in November 2008. See Brief for United States as
Amicus Curiae 5, n. 1.
Footnote 5
Catlin and the other authorities
cited in this Part interpret the meaning of “final decisions” in 28
U. S. C. §1291, the statute governing appeals from district
courts to the courts of appeals. We find them instructive in
interpreting the parallel term “final” judgment in §2101(b).
Footnote 6
As framed by the District Court, the issue
was whether the Alabama Supreme Court’s decisions in
Stokes v.
Noonan and
Riley v.
Kennedy should have been precleared. See 445 F. Supp.
2d, at 1336. This formulation, we conclude, misstates the issue in
two technical respects. First, §5 requires a covered jurisdiction
to seek preclearance of any changed “practice … with respect to
voting.” 42 U. S. C. A. §1973c(a) (Supp. 2007). The
“practice” at issue here is gubernatorial appointment. That
practice, and not the Alabama Supreme Court’s interpretation of
state law in
Stokes and
Kennedy, is the proper
subject of the §5 inquiry. Second, as Governor Riley noted, see
Brief for Appellant 25, if there was a change requiring
preclearance, it came about as a result of
Stokes, not
Kennedy.
Stokes held that the 1985 Act violated
the Alabama Constitution, and the State accordingly reinstated the
practice of gubernatorial appointment with the Governor’s 1988
appointment of Jones.
Kennedy simply determined that the
2004 Act did not resurrect the 1985 Act; that decision itself
prompted no change in the State’s election practices.
Footnote 7
By its terms, §5 requires preclearance of any
election practice that is “different from that in force or effect
on” the relevant coverage date—in this case, November 1, 1964. 42
U. S. C. A. §1973c(a) (Supp. 2007). Governor Riley’s
opening brief suggested that this text could be read to mean that
no preclearance is required if a covered jurisdiction seeks to
adopt the
same practice that was in force or effect on its
coverage date—even if, because of intervening changes, that
practice is different from the jurisdiction’s baseline. See Brief
for Appellant 26–27. In response, Kennedy and the United States
noted that the DOJ, see 28 CFR §51.12 (2007), and the lower courts
to consider the question, see,
e.g., NAACP, DeKalb
Cty. Chapter v.
Georgia, 494 F. Supp. 668, 677
(ND Ga. 1980) (three-judge court), have rejected this
interpretation. See Brief for Appellees 47–49; Brief for United
States as
Amicus Curiae 17–18. We need not resolve this
dispute because the result in this case is the same under either
view. But see
post, at 2–3 (taking the issue up, although
it is academic here).
Footnote 8
Under the “numbered post” system, “the two
commissioner posts were designated by number, and each candidate
for commissioner specified the post for which he or she sought
election.”
City of Lockhart v.
United States,
460 U. S. 125, 127 (1983) (internal
quotation marks omitted). It contrasted with an alternative system
“in which all of the candidates … run in a single election, and the
two receiving the greatest number of votes are elected.”
Id., at 127, n. 1.
Footnote 9
We commented in this regard that the
longevity of the numbered-post system “suggest[ed] a presumption of
legality under state law.”
Id., at 132, n. 6.
Footnote 10
The dissent observes that the Alabama Supreme
Court’s decision in
Stokes was not unanimous. See
post, at 8–9. Like this Court, the Alabama Supreme Court
does not shy away from revealing dissenting opinions. Of course, it
is the majority opinion that declares what state law is.
Footnote 11
As earlier noted, see
supra, at 8–9,
n. 4, the Alabama Legislature modified the relevant state law
in 2006 by adopting special elections on a going-forward basis.
Footnote 12
There is no indication in the record that the
Alabama Supreme Court’s decisions in
Stokes and
Kennedy were anything other than reasonable and impartial
interpretations of controlling Alabama law.
Footnote 13
In view of these limitations, the concern
expressed in Part IV of the dissent, see
post, at 9–13, is
misplaced. The Alabama Supreme Court’s historical role in
administering the State’s discriminatory literacy test, the dissent
contends, “indicates that state courts must be treated on the same
terms as state legislatures for §5 purposes,”
post, at 9.
But it is common ground that a “change” made pursuant to a
state-court order is subject to §5 scrutiny; the only question is
whether the Alabama Supreme Court’s ruling in
Stokes
triggered a “change” within the meaning of our decisions. See
supra, at 11;
post, at 8. More importantly, none
of the past discriminatory actions by the state court identified in
the dissent would have been sheltered from §5 review by our tightly
bounded decision in this case.
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