In the case of United States v. Board of Commissioners of Sheffield, Alabama et al., 1977, the U.S Supreme Court ruled that a city's at-large system for electing commissioners violated Section 2 of the Voting Rights Act because it diluted African-American voting strength. The court found that although there was no evidence to suggest intentional racial discrimination in establishing or maintaining this electoral system, its impact resulted in less opportunity for black citizens to participate effectively in political processes and elect representatives who could address their specific concerns. This ruling set an important precedent by recognizing that discriminatory effects alone can be sufficient grounds for finding violations under the Voting Rights Act even without proof of discriminatory intent.

In the dissenting opinion for United States v. Board of Commissioners of Sheffield, Alabama et al., Justice Powell argued that the majority's decision to allow a private plaintiff to seek relief under Title VI was misguided. He contended that Congress intended only federal agencies and departments to enforce compliance with this law, not individual citizens. Furthermore, he expressed concern over potential misuse or abuse by private plaintiffs who might use lawsuits as leverage in negotiations with federally funded programs or institutions. In addition, Justice Powell disagreed with the majority’s interpretation of legislative history and statutory language related to Title VI enforcement provisions. Finally, he warned about possible negative implications on separation-of-powers principles if courts were allowed to create remedies not explicitly provided for by Congress.