In the case of McCain et al. v. Lybrand et al., 1983, the United States Supreme Court addressed a dispute over voting rights in South Carolina's Georgetown County School District. The plaintiffs argued that changes to election procedures for school board members violated Section 5 of the Voting Rights Act, which requires certain jurisdictions with histories of racial discrimination to obtain federal approval before changing any voting practices or procedures. The defendants contended that they were not required to seek such approval because these changes had been ordered by a federal court as part of an earlier desegregation order and thus were exempt from Section 5 requirements under what is known as the "court-ordered plan" exception. The Supreme Court disagreed with this argument and held that even if a change in election procedure was initially mandated by a court order, subsequent modifications made without explicit judicial direction must still comply with Section 5 preclearance requirements. This decision underscored the importance of maintaining robust protections against potential voter discrimination and clarified how those protections apply within complex legal contexts involving other types of civil rights litigation.

In the dissenting opinion for McCain et al. v. Lybrand et al., Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision was a departure from established precedent regarding Section 5 of the Voting Rights Act. They contended that any voting changes in jurisdictions covered by Section 5 must be precleared either administratively or judicially before they can take effect to prevent discriminatory practices. The dissenters believed that South Carolina's failure to seek such approval invalidated its annexation actions and subsequent elections held under those conditions should not have been allowed to stand unchallenged as it undermines Congress' intent behind enacting Section 5 - preventing racial discrimination in voting procedures without requiring private litigation on every occasion.