The Dallas County, Alabama v. Reese case in 1974 revolved around the Voting Rights Act of 1965 and its application to local elections. The plaintiffs alleged that a requirement for candidates to pay a filing fee was discriminatory against black citizens who were less likely to afford it, thus violating Section 5 of the act which prohibits any change in voting procedures without federal approval. However, the Supreme Court ruled against them stating that Section 5 only applied when changes had been made with a discriminatory purpose or effect on racial minorities' right to vote. Since there was no evidence suggesting such intent or impact from imposing filing fees and because they were not new but rather longstanding requirements predating the Voting Rights Act itself, their enforcement did not require federal clearance under Section 5 according to this ruling.

In the dissenting opinion for Dallas County, Alabama v. Reese et al., Justice William O. Douglas argued that the majority's decision was a departure from previous interpretations of the Voting Rights Act of 1965 and its amendments in 1970 and 1971. He contended that these laws were designed to eliminate all barriers preventing black citizens from voting, not just those specifically mentioned in federal law at the time they were passed. The majority ruling held that literacy tests could be used as long as they weren't discriminatory on their face or applied unfairly; however, Douglas believed this interpretation allowed states too much leeway to create new obstacles for black voters under different guises. Furthermore, he criticized his colleagues' narrow reading of Congressional intent behind these acts which he felt should have been interpreted broadly to protect minority voting rights.