Abbott Laboratories v. Unlimited Beverages

Defendants the Dallas County Commission, various county officials, and the United States appeal the district courts order vacating its 1988 injunction which established a new election scheme for the County Commission of Dallas County, Alabama as a remedy for a violation of section 2 of the Voting Rights Act. The district court found that the 1988 injunction changed the size of the County Commission and was therefore an impermissible remedy for a voting rights violation in light of recent Supreme Court and Eleventh Circuit precedent. Because the district court did not clearly err in finding that the 1988 injunction changed the size of the County Commission, and because the law prohibiting changes in the size of a governing body in order to remedy a section 2 violation is plain, we conclude that the district court did not abuse its discretion in vacating the 1988 injunction and affirm its order.