The City of Lockhart v. United States case in 1982 revolved around the Voting Rights Act, specifically Section 5 which requires certain jurisdictions to obtain federal preclearance before implementing changes to their voting laws or procedures. The city of Lockhart, Texas sought approval for a redistricting plan that would have altered the composition of its city council districts. However, the U.S Department of Justice objected on grounds that it diluted minority voting strength and was therefore discriminatory under Section 5. The Supreme Court ruled against the City of Lockhart by upholding that any change with respect to voting can't be enforced until approved by specified federal authorities who must determine whether it has a discriminatory effect. This includes not just new laws but also adoption or enforcement of any 'standard, practice or procedure' different from what was previously in force. In this case, even though there were no allegations about intentional discrimination and despite compliance with one-person-one-vote requirement through equal population distribution across districts; because minority voters were less able than white voters to elect representatives due to proposed changes - they violated section 5's non-discrimination mandate.

In the dissenting opinion for the City of Lockhart v. United States case, Justice Powell argued that Congress did not intend to subject all changes in voting procedures to preclearance under Section 5 of the Voting Rights Act. He believed that only those changes which had a potential discriminatory effect should be subjected to such scrutiny. The majority's interpretation, he contended, would lead to an unnecessary administrative burden and could potentially deter local governments from making beneficial procedural modifications due to fear of litigation or denial by federal authorities. Furthermore, he asserted that this broad interpretation was inconsistent with principles of federalism and state sovereignty as it required states and municipalities who were previously found guilty of discrimination but have since remedied their practices, continue being treated as if they are still violating civil rights laws.