In the case of Janice G. Clark et al. v. Charles 'Buddy' Roemer, Governor of Louisiana, et al., 1990, the U.S Supreme Court dealt with a dispute over redistricting in Louisiana following the 1980 census. The plaintiffs argued that the state's reapportionment plan violated their Fourteenth Amendment rights by diluting African-American voting strength and thus discriminating against them based on race. The District Court initially ruled in favor of defendants but was reversed by an appeal court which found that there was indeed racial discrimination involved in drawing district lines under this plan and ordered to create new districts maximizing black voter strength wherever possible without violating traditional principles like compactness or respect for political subdivisions boundaries etcetera. The Supreme Court affirmed this decision stating that while creating majority-minority districts is not always necessary to remedy Voting Rights Act violations; it may be required when such action would address identified racial vote dilution effectively without leading to other significant inequities.

In the dissenting opinion for Clark v. Roemer, Justice Marshall argued that Louisiana's electoral system was inherently discriminatory against black voters and therefore violated Section 2 of the Voting Rights Act. He criticized the majority's decision to uphold a district court ruling which found no violation because it did not consider evidence of past discrimination in its analysis. According to him, this approach ignored how historical racial bias could still impact present-day voting patterns and outcomes. Furthermore, he disagreed with their interpretation of "totality of circumstances" test as requiring proof that minority group has less opportunity than other members of electorate to participate in political process and elect representatives; instead he believed any discriminatory effect should be enough for a violation finding under Section 2 regardless if caused by current practices or lingering effects from past ones. Lastly, he expressed concern over potential implications on future cases involving claims about racially polarized voting since majority’s decision might discourage lower courts from considering relevant history when evaluating them.