In the case of Hathorn et al. v. Lovorn et al., 1981, the U.S Supreme Court ruled that a Mississippi law requiring voters to be residents in a school district for two years before they could vote on school bond issues was unconstitutional. The court found that this residency requirement violated the Equal Protection Clause of the Fourteenth Amendment as it denied some citizens within these districts their right to vote based solely on how long they had lived there. This ruling reaffirmed that any state laws which place restrictions on voting rights must meet strict scrutiny standards and demonstrate a compelling state interest; something Mississippi's residency requirement failed to do.

In the dissenting opinion for Hathorn et al. v. Lovorn et al., Justice Powell, joined by Chief Justice Burger and Justices Stewart and Rehnquist, argued that the majority's decision to overturn Mississippi's voting plan was based on an incorrect interpretation of Section 5 of the Voting Rights Act. The dissenters believed that this section only required preclearance for changes with a discriminatory purpose or effect, not all changes as interpreted by the majority. They also disagreed with applying this requirement retroactively to Mississippi’s 1975 law change which had already been implemented in several elections without any objections from federal authorities or private parties about racial discrimination issues until now. Furthermore, they pointed out that there were no findings showing intentional racial discrimination in adopting these laws nor their implementation having such effects; thus it should be presumed valid under state sovereignty principle unless proven otherwise – something plaintiffs failed to do so according to them.