By: Lane Reeder
Prior to Shelby County v. Holder in 2013, South Carolina was a covered jurisdiction under Section Five of the Voting Rights Act. In 2011, during Legislative Session 119, the South Carolina legislature passed, and the Governor signed, an act that made voting-related changes. Section Five of Act R54 (A27 H3003) (2011) dealt with voter identification. Because this happened prior to Shelby County v. Holder, pre-clearance was required. The State asked for pre-clearance from the Attorney General of the United States, but it was denied. South Carolina then sought a declaratory judgment in the D.C. District Court.