Brnovich v. Democratic National Committee

The Court applied Section 2's totality of circumstances test to determine whether Arizona's facially neutral policies imposed unlawful discriminatory burdens on minority voters. Although statistical evidence demonstrated that the out-of-precinct ballot discard policy and third-party ballot collection ban fell more heavily on Black, Hispanic, and Native American voters, the Court found these disparate impacts insufficient to constitute a Section 2 violation when weighed against Arizona's legitimate interests in ballot integrity and administrative accuracy. The Court's framework effectively narrowed Section 2 by holding that disparate racial impact alone, even when statistically documented, does not establish a violation unless the challenged rule creates a substantial and unjustified impediment to minority electoral participation relative to the overall voting scheme.