The Alabama State Conference of the NAACP and individual voters sued Alabama under Section 2 of the Voting Rights Act, challenging an election practice as racially discriminatory. Alabama argued that the Eleventh Amendment barred private suits against the State. The Eleventh Circuit affirmed the district court and held that Congress validly abrogated state sovereign immunity for private Section 2 enforcement actions. The court examined the Voting Rights Act’s text, its enforcement structure, and the constitutional authority supporting the Act’s protection of voting rights. A dissent argued that the majority had abandoned the Supreme Court’s requirement for an unmistakably clear statement of congressional intent to abrogate immunity and would have dismissed Alabama from the case.