In the 1986 case City of Pleasant Grove v. United States, the Supreme Court ruled that a city's at-large electoral system was in violation of Section 2 of the Voting Rights Act due to its discriminatory effect on black voters. The city of Pleasant Grove, Alabama had an at-large voting system where all voters could vote for all members of the city council. However, this resulted in no African American representation despite making up about 62% percent population because white residents consistently voted as a bloc to defeat black candidates. The court found that under these circumstances, such an electoral system denied African Americans equal opportunity "to participate in the political process and to elect representatives of their choice," violating federal law.

In the dissenting opinion for CITY OF PLEASANT GROVE v. UNITED STATES, 1986, Justice Stevens argued that the majority's decision was inconsistent with previous rulings on voting rights cases. He contended that the city of Pleasant Grove had violated Section 2 of the Voting Rights Act by diluting minority votes through its at-large electoral system and thus preventing black citizens from having an equal opportunity to participate in political processes. The justice also disagreed with the majority's view about what constitutes a violation under Section 2, arguing it should not be limited to instances where minorities have less opportunity than whites to elect representatives of their choice but should include any practice or procedure which results in unequal access to any aspect of a state’s electoral process.