In the case of Rogers et al. v. Lodge et al., 1981, the U.S. Supreme Court upheld a lower court's ruling that Burke County, Georgia's at-large method for electing county commissioners was racially discriminatory and violated Section 2 of the Voting Rights Act. The plaintiffs argued that this system diluted African American voting strength and perpetuated racial discrimination in violation of their Fourteenth Amendment rights to equal protection under law and Fifteenth Amendment right against racial discrimination in voting practices. The defendants contended there was no proof of intentional discrimination or any discriminatory impact from this electoral system on minority voters' ability to participate equally in elections or elect representatives of their choice. The Supreme Court ruled by a vote of six-to-three that intent is not necessary to prove violations under Section 2; it suffices if an electoral practice has been maintained which results in denying protected minorities an equal opportunity to participate meaningfully and effectively in political processes. This landmark decision significantly expanded protections for minority voters against potentially discriminatory election systems even where no explicit intentionality could be demonstrated, thereby strengthening enforcement provisions within federal civil rights laws protecting voting rights.

In the dissenting opinion for Rogers v. Lodge, Justice Powell argued that the majority had failed to properly apply the intent standard established in previous voting rights cases. He contended that while racial discrimination was a shameful part of Burke County's past, there was insufficient evidence to suggest it continued to influence its present electoral system. The fact that black citizens were underrepresented on the county commission did not necessarily mean they were being denied equal access to political processes; other factors such as socioeconomic status could also be at play. Furthermore, he criticized the majority for suggesting alternative electoral systems without considering whether these would actually enhance minority representation or simply divide power along racial lines even more starkly.