In the case of Allen et al. v. State Board of Elections et al., 1968, the U.S Supreme Court ruled that any change in election procedure or practice in states with a history of racial discrimination must be pre-approved by federal authorities under Section 5 of the Voting Rights Act (VRA) to ensure it does not harm minority voting rights. The court held that this provision applied broadly and included changes such as redistricting, annexations, adoption of at-large elections, and changes to voter qualifications or prerequisites for voting. This decision was significant because it expanded federal oversight over state and local electoral practices in jurisdictions with a history of discriminatory practices against African Americans.

In the dissenting opinion for Allen et al. v. State Board of Elections et al., Justice Harlan argued that the majority's interpretation of Section 5 of the Voting Rights Act was too broad and not in line with Congressional intent. He contended that Congress intended to target only those changes in voting procedures which had a discriminatory purpose, rather than any change affecting voting at all as interpreted by the majority. Furthermore, he disagreed with applying this section to state laws requiring candidates to be residents or receive a certain number of votes before being elected, arguing these were non-discriminatory requirements unrelated to racial discrimination issues addressed by the Act. Additionally, he criticized how broadly 'voting' was defined by his colleagues and expressed concern over federal courts becoming overly involved in local election processes due their new role as arbiters whether changes should be allowed under Section 5.