The U.S. Supreme Court case City of Richmond, Virginia v. United States et al., 1974 revolved around the Voting Rights Act of 1965 and its application to a proposed annexation by the city of Richmond, Virginia. The city sought to annex portions of Chesterfield County which would have increased its white population and diluted black voting strength in violation with Section 5 of the Voting Rights Act that prohibits any changes in election procedures or district lines that could potentially discriminate against minority voters without pre-clearance from either federal court or Department Of Justice (DOJ). The Supreme Court held that this proposed annexation was indeed subject to review under Section 5 as it constituted a change affecting voting rights. Furthermore, they ruled that since DOJ had not granted pre-clearance for this action, it was prohibited from taking effect.

In the dissenting opinion for the case of City of Richmond, Virginia v. United States et al., 1974, it was argued that the majority's decision to strike down a city annexation plan on grounds of racial discrimination was flawed. The dissenters believed that there wasn't sufficient evidence to prove intentional racial discrimination by Richmond officials in their annexation plans. They contended that while demographic changes resulting from an action might have racially disparate impacts, this does not necessarily mean they were enacted with discriminatory intent or purpose. Furthermore, they expressed concern about federal courts intervening excessively in local government affairs and warned against setting a precedent where any governmental action causing demographic change could be challenged as racially discriminatory without clear proof of intent.