In the 1984 case Hunter et al. v. Underwood et al., the U.S Supreme Court unanimously ruled that an Alabama law, which disenfranchised individuals convicted of crimes involving moral turpitude, was unconstitutional due to its racially discriminatory intent and impact. The court found that although facially neutral, the law had been enacted with a racially discriminatory purpose during a constitutional convention in 1901 aimed at establishing white supremacy by suppressing black voters' rights. The evidence showed that it disproportionately affected African Americans compared to whites committing similar offenses and thus violated equal protection under the Fourteenth Amendment of the Constitution.

In the dissenting opinion for Hunter et al. v. Underwood et al., Justice Rehnquist disagreed with the majority's interpretation of Section 182 of Alabama's Constitution, which disqualified individuals from voting if they had committed crimes involving "moral turpitude." The majority ruled that this provision was racially discriminatory and therefore violated the Equal Protection Clause of the Fourteenth Amendment. However, Justice Rehnquist argued that there was insufficient evidence to prove racial discrimination in either its original intent or its contemporary application. He contended that moral turpitude is a broad term encompassing many non-racially specific crimes such as perjury or forgery, thus it could not be assumed to target black voters specifically. Furthermore, he pointed out that African Americans were not disproportionately affected by this law at present time; hence it should not be deemed unconstitutional on those grounds.