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non-retrogression requirements where the affected jurisdiction was able to prove there
was no racial discrimination.
225. Mobile v. Bolden, 446 U.S. 55 (1980). In Rogers v. Lodge, 458 U.S. 613 (1982), the
Court held that an "at large" system of voting rather than using districts for County
Commissioners violated §2 because, although it was not adopted for racially
discriminatory reasons, it was maintained because it had a racially discriminatory effect.
226. Dobson v. Mayor and City Council of Baltimore, 330 F. Supp. 1290 (D. Md. 1971).
227. Matter of Legislative Districting of State, 299 Md. 658 (1982, opinion issued 1984).
228. 42 U.S.C. § 1973 as amended by the Voting Rights Act Amendments of 1982.
229. 478 U.S. 30(1986).
230. CONSTITUTION OF MARYLAND, Art. VII, § 1.
231. Although the Supreme Court has held that the at large election is not perse a violation of
the equal protection clause, [Whitcomb v. Chavis, 403 U.S. 124 (1971)], it has found that
such systems were used with an invidious purpose in a number of cases, [White v.
Regester, 412 U.S.755 (1973), Rogers v. Lodge, 458 U.S. 613 (1982)].
232. United States v. Dorchester County, Maryland et al., Civil Action No. R^84.-4410 (D.
Md. filed Dec. 5, 1984; consent agreement approved July 8, 1985).
233. See Padgett v. Commissioners, Somerset County, 1989 U.S. Dist. LEXIS 5096 (Suit over
attorney's fees on consent agreement).
234. See Alexander v. Mayor and Council of Town of Cheverly, 1992 WL 2004 (4th Cir.
(Md.) (Attorneys fees litigation upholding only partial fees on grounds that voter only
prevailed/ in part because municipality had committed itself to redistricting and lawsuit
only contributed to timing of the redistricting.)
235. Anne Arundel County Republican Central Committee v. State Advisory Board of
Election Laws, 1991 WL 283865 (D. Md. Dec. 23, 1991).
236. 401 U.S. 424 (1971).
237. The Supreme Court held in Washington v. Davis. 426 U.S. 229 (1976), that
discriminatory intent was an essential element of a cause of action for deprivation of a
constitutional right and in General Building Contractors Assn. V. Pa.. 458 U.S. 375
(1982) that it is also an essential element of §1981 claim.
238. Discussion of the differences in scope, procedure and remedy between Title VII and
§1981 will be left to the course in Employment Discrimination.
229
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