The 1980s began inauspiciously for supporters of minority voting rights when a plurality
of the Supreme Court ruled in City of Mobile v. Bolden (1980) that the Voting Rights Act
prohibited only intentional discrimination. Yet two years later, civil rights forces, over Reagan
Administration objections, amended the Act to make clear that it was meant to prohibit laws or
practices that had either the intent or the effect of discriminating against people on the basis of
race. The bipartisan consensus in favor of a strengthened Voting Rights Act, the explicit
standards in the authoritative Senate report on the Act, and the attention and elan that the 1981-
82 struggle restored to voting rights carried the movement to successes through the rest of the
1980s. At-large elections like those at issue in Bolden were declared illegal in many areas in the
South and some outside it
