2 Announcing that “history did not end in 1965” 3 and that “ur country has changed,” Chief Justice Roberts, writing for the conservative majority of the Court, ruled that the geographic coverage formula contained in section 4(b) and used to identify jurisdictions subject to section 5 was outdated and could no longer be constitutionally justified. 1 Under that provision, most states of the former Confederacy had been required to “preclear” changes to their voting laws and practices with a federal court in Washington, D.C., or with the Department of Justice to ensure those changes did not deny or abridge the right to vote on the basis of race. On June 25, 2013, the Supreme Court invalidated the geographic coverage formula of the 1965 Voting Rights Act, effectively abrogating the preclearance requirement in section 5 of the Act.
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