Louisiana v. Callais · ¶133

Congress's initial efforts to counter voting discrimination—in the Civil Rights Acts of 1957, 1960, and 1964—did little but prove the difficulty of the task. Each of those statutes authorized the Attorney General “to seek injunctions against public and private interference with the right to vote on racial grounds.” Katzenbach, 383 U. S., at 313. But time and again, States found ways to evade the ensuing court orders. They “merely switched to discriminatory devices not covered by” the court decrees, finding yet new race- neutral rules (there seemed an endless number) that would maintain the disparity between White and Black voting power. Id., at 314. Congress thus learned of the “unremitting and ingenious” methods States could use to resist African American enfranchisement. Id., at 309. Protecting minority voting was like “battling the Hydra”: “Whenever one form of voting discrimination…

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