In the case of Perkins et al. v. Matthews, Mayor of the City of Canton, et al., 1970, African American residents in Canton, Mississippi challenged changes to city boundaries that they argued were designed to dilute their voting power and maintain white control over municipal government. The Supreme Court ruled in favor of the plaintiffs by a vote of 8-1 on March 23rd, 1970 stating that any change with respect to voting different from what was previously practiced must be submitted for approval under Section Five before it can be implemented as per Voting Rights Act (1965). This includes alterations such as changing polling places or redrawing district lines which could potentially discriminate against racial minorities. The court held that these modifications had not been approved federally and thus violated this act.

In the dissenting opinion for Perkins et al. v. Matthews, Mayor of the City of Canton, et al., Justice Harlan argued that there was no sufficient evidence to prove a violation of Section 5 of the Voting Rights Act by city officials in changing polling locations without federal approval. He pointed out that it is not clear whether such changes would have had any discriminatory effect on black voters as alleged by plaintiffs and thus did not necessarily require preclearance under Section 5. Furthermore, he expressed concern over judicial overreach and cautioned against courts intervening too readily in local election procedures which could potentially undermine local autonomy and self-governance.