In the case of Wood et al. v. Georgia, 1980, Sheriff Derwin Wood and his deputies were found guilty by a lower court for violating the Voting Rights Act by intimidating black voters in their county during an election. The Supreme Court overturned this decision on appeal because it was based on statistical evidence rather than direct proof of intimidation or coercion. The Court held that while statistics can be used to prove discrimination in some cases, they are not sufficient to establish guilt beyond reasonable doubt in criminal proceedings where individual rights are at stake. Therefore, without concrete evidence showing that Sheriff Wood and his deputies intentionally intimidated black voters with the purpose of interfering with their right to vote freely, they could not be convicted under the Voting Rights Act.

In the dissenting opinion for Wood et al. v. Georgia, Justice Brennan disagreed with the majority's decision to remand the case back to state court without first addressing whether or not there was a constitutional violation in this instance of jury selection. He argued that by doing so, they were avoiding their duty as Supreme Court justices to interpret and uphold constitutional law. Furthermore, he expressed concern over how this could potentially allow states to continue discriminatory practices in jury selection unchallenged by federal courts if they simply claimed ignorance of such discrimination occurring within their jurisdiction.