Allen v. State Bd. of Elections

In Allen v. State Bd. of Elections, 393 U.S. 544, 567, 89 S.Ct. 817, 22 L.Ed.2d 1 (1969), the Supreme Court observed that 2(a) of the VRA, as originally drafted, included only a prohibition against any voting "qualification or procedure." 393 U.S. at 566, 89 S.Ct. 817. After concerns were raised that this language may not be sufficiently expansive to cover all practices that could deny individuals the right to vote on account of their race, Congress expanded the language in the final version to include any "voting qualifications or prerequisites to voting, or standard, practice, or procedure." Id. at 567, 89 S.Ct. 817 (quoting 42 U.S.C. 1973(a)). The Supreme Court viewed this change as "indicative of Congress's intention to give the Act the broadest possible scope." Allen, 393 U.S. at 566-67, 89 S.Ct. 817.