About the Project

The Voting Rights Initiative (VRI) at the University of Michigan Law School (UMLS) explores how Section 2 of the Voting Rights Act operates over time. VRI’s 2006 report documented Section 2 claims brought between June 29, 1982, and December 31, 2005 that resulted in one or more decisions published or available on Westlaw or Lexis. A draft of the 2006 report and accompanying database were included in the evidentiary record assembled by Congress when it reauthorized the Voting Rights Act in 2006. Subsequent judicial rulings addressing the constitutionality of the 2006 reauthorization relied on the report.

In early 2022, we published this website and database documenting Section 2 litigation from June 29, 1982 through December 31, 2021. The database includes judicial decisions that addressed a substantive Section 2 claim during this period and were published or made available on Westlaw or Lexis. The dataset does not include cases that cited or discussed Section 2 independent of a substantive claim. It also omits cases in which the Section 2 claim appeared frivolous and cases in which the merits decision was vacated on appeal.

In contrast to our 2006 report, which examined every opinion issued in a given case, the 2022 database includes only what we have labeled the “final word” ruling. In most lawsuits, the final word decision is the merits decision that determined whether Section 2 was violated. Absent a direct decision on the merits, the final word case is the last published case in the lawsuit that made a substantive determination for or against the plaintiff. Final word opinions can include rulings on a preliminary injunction, evidentiary disputes, judicial approval of a settlement, a remedial order, and attorneys’ fees. In instances where the final word opinion focused on a secondary issue, the contours of the underlying Section 2 claim and the court’s Section 2 analysis were not always clear. Still, these cases, particularly preliminary injunction cases, often included some substantive assessment of Section 2 criteria that researchers documented. Cases in which nothing more than the fact of decision was evident from the opinions were included so long as the opinion appeared to rest at least in part on a substantive Section 2 claim.

The 2022 dataset includes a coded final word opinion for every case appearing in the 2006 report. Because the 2022 dataset focuses on the final word case, while the 2006 report included all substantive rulings in a litigation string, some differences between the two datasets arise. The two approaches yielded few aggregate differences, but in a handful of cases the 2022 dataset reports findings for specific cases that differ from the findings reported in the 2006 report.

Finally, note that because our dataset only examines published opinions or opinions that are available through Westlaw or Lexis, any Section 2 case that did not result in such an opinion is not represented here. Additionally, we have not included cases that are still being litigated. This necessarily means that our dataset undercounts all Section 2 cases, and also undercounts cases brought in the last several years that remain active.

The dataset is current as of December 31, 2021. A PDF version of the information contained on this website is available for download.

Definitions and Coding Practices

The Section 2 cases in our dataset were coded along 50 criteria. Terms and categories that may not be self-evident are defined here. For more information on coding practices or the dataset, see our codebook.

  • Appointment/State Control: These are Section 2 challenges to a state’s authority to change elected positions to appointed positions, to shrink or enlarge the duties of an elected position, or to allow one set of positions to be elected while a similar set of positions were appointed.
  • Dilution: The effect of an electoral practice that minimizes the influence of a particular group of voters. Practices found to be dilutive within the meaning of Section 2 include at-large elections, redistricting plans, and majority vote requirements.
  • Considered and Unconsidered Factors: Whether a reviewing court considered and/or found any of the three Gingles preconditions or any of the nine Senate Factors. Occasionally, the court discussed a factor but did not make a determination as to whether the factor had been satisfied; in those instances, the factor was left blank.
  • Election Procedures: Electoral rules addressing early voting, voter registration, voter identification, election scheduling, and related measures. These cases are categorized as a subset of non-dilution.
  • Fees: A final word decision that addressed a post-liability issue such as attorneys’ fees.
  • Final Word: Our term for the final decision in a Section 2 litigation string. In most lawsuits, the final word decision is the most thorough merits decision that both determined whether Section 2 was violated and which was not reversed on appeal. Absent such a final word decision, the database includes the last published decision in the lawsuit that made a substantive ruling on any topic. When an appellate opinion specifically stated that it was agreeing with, concurring with, or otherwise incorporating analysis from a lower court opinion on Gingles preconditions or Senate factors without reciting that analysis, the researchers included the analysis found in the district court’s opinion. Researchers similarly incorporated the lower court’s findings if the appellate court stated that no party challenged a particular finding.
  • Intent: A case was coded as finding discriminatory intent if the court explicitly ruled that the defendants engaged in intentional voting discrimination, either under Section 2 or under the Fourteenth Amendment. If the court did not make an explicit determination regarding intentional discrimination, this field was left blank.
  • Jurisdiction Covered/Not Covered By Section 5: Researchers determined if a claim arose in a jurisdiction that had been subject to the Section 5 preclearance regime because either the case arose in a jurisdiction that fell within the Section 4(b) coverage formula prior to the Supreme Court’s decision in Shelby County, or because the case arose in a jurisdiction within a larger jurisdiction that fell under the coverage formula. Researchers coded a jurisdiction as being covered if the jurisdiction was on this list. If a jurisdiction was itself not covered but contained covered jurisdictions, researchers attempted to discern if the challenged practice would affect voters in the covered jurisdictions. If so, the case was coded as occurring in a jurisdiction that was covered by Section 4(b). If not, the case was coded as not covered.
  • Liability: A final word decision that addressed the merits of a Section 2 claim. Liability decisions typically resolved a motion to dismiss, a motion for summary judgment, announced a verdict after trial, or resolved an appeal of such decisions.
  • Non-dilution: Also known as “vote denial” or “time, place, and manner” claims, non-dilution claims are Section 2 claims that address election procedures, ballot design, felon disenfranchisement statutes, and related measures.
  • Plaintiff Group: Cases were categorized by the ethnicity of the plaintiff group or groups bringing the Section 2 challenge, and, specifically, whether the plaintiffs were Black, Latino, American Indian, Asian American, or white. Many cases included plaintiffs of more than one ethnicity. A small portion of dilution cases, coded as “coalition” claims, were brought by two or more plaintiff groups alleging that, together, they were injured by the challenged electoral practice. Finally, the few cases coded as having no plaintiff ethnicity involved a challenge to a racial classification or another practice on behalf of all voters, or did not specify the plaintiff’s ethnicity.
  • Plaintiff Success: A case was coded as successful for the plaintiff if it resulted in a change to a challenged practice. Successes include:
    • Issuance of a preliminary injunction, a finding for a plaintiff on the merits, a decision issuing attorneys’ fees in a manner that indicated a plaintiff had been successful on the merits or through settlement, or if the plaintiff achieved some other positive outcome.
    • Cases involving multiple Section 2 claims in which plaintiffs were successful on at least one.
    • Fees or remedy cases in which defendants stipulated that the challenged practice had violated Section 2, even if plaintiffs were unable to obtain attorneys’ fees or the post-settlement relief sought.
  • Preliminary: A final word decision on the issuance of a preliminary injunction, evidentiary issue, or other ruling prior to a merits Section 2 claim.
  • Violation: A case was coded as a violation if the court found, or the parties stipulated, that the challenged practice was a violation of Section 2.

A note on cases, claims, and successful Section 2 challenges: Cases that involved multiple Section 2 claims were coded as a single case. The number of cases containing multiple distinguishable claims was small, and  dividing  the cases into individual claims threatened to  confuse, rather than clarify, the results of the study. In a small number of cases, case-dependent coding leads to odd results: for instance, both LULAC v. Perry and Abbott v. Perez are coded as plaintiff successes even though, in each case, only one of several challenged districts was struck down under Section 2.

Finally, while the VRI team made every effort to code cases consistently and accurately, judicial reasoning, legal opinions, and the underlying fact patterns often defy easy categorization. Please report any errors, or direct any questions, to law-votingrightsinitiative@umich.edu.

Our Team

Ellen D. Katz (Ralph W. Aigler Professor of Law, UMLS); Elizabeth Jones (UMLS ’17), Kaylie Springer (UMLS ’18), James Coatsworth (UMLS ’18), Anna Hall (UMLS ’19), Micah Telegen (UMLS ’19), Rose Lapp (UMLS ’20), Jacob Muller (UMLS ’20), Mackenzie Walz (UMLS ’20), Brian Remlinger (UMLS ‘21), Andrew Dziedzic (UMLS ‘22), Brooke Simone (UMLS ‘22), and Jordan Schuler (UMLS ‘24).

Student Researchers

Helen Marie Berg (UMLS ’18), Dani Bernstein (UMLS ’21), James Brokaw (UMLS ’21), Joseph Condon (UMLS ’20), Kathleen Craddock (UMLS ’18), Andrew Cutillo (UMLS ’20), Ciara Davis (UMLS ’18), Kristin Froehle (UMLS ’19), Claire Grace (UMLS ’21), Joshua Goldman (UMLS ’19), Asma Husain (UMLS ’18), Gabriela Hybel (UMLS ’19), Betsy Johnson (UMLS ’21), Adam Kleven (UMLS ’18), Tommy La Voy (UMLS ’19), Joe Lindblad (UMLS ’21), Antonia Lluberes (UMLS ’21), Amita Maram (UMLS ’21), Seth Mayer (UMLS ’23), Laura Mebert (UMLS ’23), Caleb Nagel (UMLS ’18), Dhruti Patel (UMLS ’20), Bradley Puffenbarger (UMLS ’18), Hannah Rubashkin (UMLS ’19), Matt Thornburg (UMLS ’19), Eli Wachtel (UMLS ’20), Will Walker (UMLS ’21), Becky Wasserman (UMLS ’21), Virginia Weeks (UMLS ’18), and Sam White (UMLS ’21).


Many thanks to Alice Liu (UMLSA ’21), Ewelina Papiez (UMSI ’22), and Smrithi Srinivasan (UMSI ’22) for designing this website, Alex Lee and the Communications staff at the University of Michigan Law School, and Lyle Whitney and the IT staff at the University of Michigan Law School.

Jurisdictions Covered by the Section 4(b) Preclearance Formula

  • States covered as a whole
      • Alabama
      • Alaska
      • Arizona
      • Georgia
      • Louisiana
      • Mississippi
      • South Carolina
      • Texas
      • Virginia
  • Covered counties in states not covered as a whole
    • California:
      • Kings County
      • Monterey County
      • Yuba County
    • Florida:
      • Collier County
      • Hardee County
      • Hendry County
      • Hillsborough County
      • Monroe County
    • New York:
      • Bronx County
      • Kings County
      • New York County
    • North Carolina:
      • Anson County
      • Beaufort County
      • Bertie County
      • Bladen County
      • Camden County
      • Caswell County
      • Chowan County
      • Cleveland County
      • Craven County
      • Cumberland County
      • Edgecombe County
      • Franklin County
      • Gaston County
      • Gates County
      • Granville County
      • Greene County
      • Guilford County
      • Halifax County
      • Harnett County
      • Hertford County
      • Hoke County
      • Jackson County
      • Lee County
      • Lenoir County
      • Martin County
      • Nash County
      • Northampton County
      • Onslow County
      • Pasquotank County
      • Perquimans County
      • Person County
      • Pitt County
      • Robeson County
      • Rockingham County
      • Scotland County
      • Union County
      • Vance County
      • Washington County
      • Wayne County
      • Wilson County
    • South Dakota:
      • Shannon County
      • Todd County
  • Covered townships
    • Michigan
      • Clyde Township
      • Buena Vista Township