In the 1993 case of Bolley Johnson, Speaker of the Florida House of Representatives, et al. v. Miguel De Grandy et al., the U.S. Supreme Court ruled on a dispute regarding redistricting in Dade County, Florida that allegedly violated Section 2 of the Voting Rights Act by diluting Hispanic voting strength. The plaintiffs argued that despite Hispanics making up over half of Dade County's population, they were only a majority in seven out of eighteen districts for state representatives and three out nine districts for state senators due to gerrymandering practices favoring non-Hispanic voters. The defendants contended that this was not discriminatory as it reflected proportional representation based on total population numbers. The Supreme Court held (5-4) that while proportionality is one factor to consider when determining vote dilution under Section 2, it is not dispositive or determinative alone; other factors such as minority group's ability to elect their preferred candidates must also be considered. Therefore, even if district lines result in roughly proportional representation for racial groups overall but still prevent them from having an equal opportunity to influence elections within specific districts due to racially polarized voting patterns - then those lines may violate Section 2.

In the dissenting opinion for Bolley Johnson, Speaker of the Florida House of Representatives, et al. v. Miguel De Grandy et al., Justice O'Connor argued that the majority's decision failed to provide clear guidance on how to reconcile conflicts between Section 2 and Section 5 of the Voting Rights Act. She expressed concern about potential confusion in future cases due to lack of clarity regarding which section should take precedence when they are at odds with each other. Additionally, she disagreed with the majority's interpretation that a minority group could claim vote dilution under Section 2 even if it had proportional representation overall because this would lead to an overemphasis on race in redistricting efforts and potentially undermine nonracial districting principles such as compactness or respect for political subdivisions.