Editing Voting Rights Act of 1965 (section)

===Amendments===
{{main|Amendments to the Voting Rights Act of 1965}}
[[File:Bush Signs Voting Rights Act of 2006.jpg|thumb|alt=refer to caption|[[President of the United States|United States President]] [[George W. Bush]] signs amendments to the Act in July 2006]]
Congress enacted major amendments to the Act in 1970, 1975, 1982, 1992, and 2006. Each amendment coincided with an impending expiration of some or all of the Act's special provisions. Originally set to expire by 1970, Congress repeatedly reauthorized the special provisions in recognition of continuing voting discrimination.<ref name=Bending />{{rp|209–210}}<ref name=RevisedBailout />{{rp|6–8}} Congress extended the coverage formula and special provisions tied to it, such as the Section 5 preclearance requirement, for five years in 1970, seven years in 1975, and 25 years in both 1982 and 2006. In 1970 and 1975, Congress also expanded the reach of the coverage formula by supplementing it with new 1968 and 1972 trigger dates. Coverage was further enlarged in 1975 when Congress expanded the meaning of "tests or devices" to encompass any jurisdiction that provided English-only election information, such as ballots, if the jurisdiction had a single language minority group that constituted more than five percent of the jurisdiction's voting-age citizens. These expansions brought numerous jurisdictions into coverage, including many not in the South.<ref name=DOJsection4>{{Source-attribution|sentence=yes|{{cite web |title=Section 4 of the Voting Rights Act|publisher=U.S. Department of Justice |url=https://www.justice.gov/crt/about/vot/misc/sec_4.php|access-date=June 25, 2013|archive-url=https://web.archive.org/web/20231104020640/https://www.justice.gov/crt/section-4-voting-rights-act|archive-date=November 4, 2023}}}}</ref> To ease the burdens of the reauthorized special provisions, Congress liberalized the bailout procedure in 1982 by allowing jurisdictions to escape coverage by complying with the Act and affirmatively acting to expand minority [[political participation]].<ref name=democracy />{{rp|523}}

In addition to reauthorizing the original special provisions and expanding coverage, Congress amended and added several other provisions to the Act. For instance, Congress expanded the original ban on "tests or devices" to apply nationwide in 1970, and in 1975, Congress made the ban permanent.<ref name=RevisedBailout />{{rp|6–9}} Separately, in 1975 Congress expanded the Act's scope to protect language minorities from voting discrimination. Congress defined "language minority" to mean "persons who are American Indian, Asian American, Alaskan Natives or of Spanish heritage."<ref name="VRA-14(c)(3)">Voting Rights Act of 1965 § 14(c)(3); {{uscsub|52|10310|c|3}} (formerly 42 U.S.C. § 1973l(c)(3))</ref> Congress amended various provisions, such as the preclearance requirement and Section 2's general prohibition of discriminatory voting laws, to prohibit discrimination against language minorities.<ref name=enfranchise>{{cite journal|last=Tucker|first=James Thomas|title=Enfranchising Language Minority Citizens: The Bilingual Election Provisions of the Voting Rights Act|journal=New York University Journal of Legislation and Public Policy|year=2006|volume=10|url=http://www.nyujlpp.org/wp-content/uploads/2012/11/TUCKER-ENFRANCHISING-LANGUAGE-MINORITY-CITIZENS-TEH-BILINGUAL-ELECTION-PROVISIONS-OF-THE-VOTING-RIGHTS-ACT.pdf|access-date=January 3, 2014|archive-date=October 20, 2013|archive-url=https://web.archive.org/web/20131020111915/http://www.nyujlpp.org/wp-content/uploads/2012/11/TUCKER-ENFRANCHISING-LANGUAGE-MINORITY-CITIZENS-TEH-BILINGUAL-ELECTION-PROVISIONS-OF-THE-VOTING-RIGHTS-ACT.pdf|url-status=dead}}</ref>{{rp|199}} Congress also enacted a bilingual election requirement in Section 203, which requires election officials in certain jurisdictions with large numbers of English-illiterate language minorities to provide ballots and voting information in the language of the language minority group. Originally set to expire after 10 years, Congress reauthorized Section 203 in 1982 for seven years, expanded and reauthorized it in 1992 for 15 years, and reauthorized it in 2006 for 25 years.<ref name=CRS>{{CRS|author=Laney, Garrine P. |date=June 12, 2008|article=The Voting Rights Act of 1965, As Amended: Its History and Current Issues|url=https://digital.library.unt.edu/ark:/67531/metadc26107/m1/1/high_res_d/95-896_2008Jun12.pdf|access-date=September 15, 2017|format=PDF|archive-url=https://web.archive.org/web/20200212181614/https://digital.library.unt.edu/ark:/67531/metadc26107/m1/1/high_res_d/95-896_2008Jun12.pdf|archive-date=February 12, 2020}}</ref>{{rp|19–21, 25, 49}} The bilingual election requirements have remained controversial, with proponents arguing that bilingual assistance is necessary to enable recently naturalized citizens to vote and opponents arguing that the bilingual election requirements constitute costly [[unfunded mandate]]s.<ref name=CRS />{{rp|26}}

Several of the amendments responded to judicial rulings with which Congress disagreed. In 1982, Congress amended the Act to overturn the Supreme Court case ''[[Mobile v. Bolden]]'' (1980), which held that the general prohibition of voting discrimination prescribed in Section 2 prohibited only ''purposeful'' discrimination. Congress responded by expanding Section 2 to explicitly ban any voting practice that had a discriminatory ''effect'', regardless of whether the practice was enacted or operated for a discriminatory purpose. The creation of this "results test" shifted the majority of vote dilution litigation brought under the Act from preclearance lawsuits to Section 2 lawsuits.<ref name=democracy />{{rp|644–645}} In 2006, Congress amended the Act to overturn two Supreme Court cases: ''Reno v. Bossier Parish School Board'' (2000),<ref name=Reno>''Reno v. Bossier Parish School Board'', {{ussc|528|320|2000}}</ref> which interpreted the Section 5 preclearance requirement to prohibit only voting changes that were enacted or maintained for a "retrogressive" discriminatory purpose instead of any discriminatory purpose, and ''[[Georgia v. Ashcroft]]'' (2003),<ref name=Ash>''[[Georgia v. Ashcroft]]'', {{ussc|539|461|2003}}</ref> which established a broader test for determining whether a redistricting plan had an impermissible effect under Section 5 than assessing only whether a minority group could elect its preferred candidates.<ref name=Promise>{{cite journal|last=Persily|first=Nathaniel|title=The Promise and Pitfalls of the New Voting Rights Act|journal=Yale Law Journal|year=2007|volume=117|issue=2|pages=174–254| doi=10.2307/20455790 |jstor=20455790|url=http://yalelawjournal.org/the-yale-law-journal/article/the-promise-and-pitfalls-of-the-new-voting-rights-act/|access-date=September 21, 2013|url-status=dead|archive-url=https://web.archive.org/web/20130926061938/http://yalelawjournal.org/the-yale-law-journal/article/the-promise-and-pitfalls-of-the-new-voting-rights-act/|archive-date=September 26, 2013}}</ref>{{rp|207–208}} Since the Supreme Court struck down the coverage formula as unconstitutional in ''[[Shelby County v. Holder]]'' (2013), several bills have been introduced in Congress to create a new coverage formula and amend various other provisions; none of these bills have passed.<ref>{{cite web|title=Moving Forward on the VRAA|url=http://www.naacpldf.org/case-issue/voting-rights-amendment-act-2014|publisher=NAACP Legal Defense and Educational Fund, Inc.|access-date=April 19, 2014}}</ref><ref>{{cite web|url=https://www.govtrack.us/congress/bills/114/hr885# |title=H.R. 885: Voting Rights Amendment Act of 2015 |publisher=govtrack.us |access-date=December 27, 2015}}</ref><ref>{{Cite web|url=https://sensenbrenner.house.gov/2017/7/reps-sensenbrenner-and-conyers-reintroduce-bipartisan-voting-rights-amendment-act-of-2017|title=Reps. Sensenbrenner and Conyers Reintroduce Bipartisan Voting Rights Amendment Act of 2017|website=Congressman Jim Sensenbrenner|language=en|access-date=November 15, 2019|archive-date=November 15, 2019|archive-url=https://web.archive.org/web/20191115021441/https://sensenbrenner.house.gov/2017/7/reps-sensenbrenner-and-conyers-reintroduce-bipartisan-voting-rights-amendment-act-of-2017|url-status=dead}}</ref>