<P> As originally enacted, the coverage formula contained only November 1964 triggering dates; subsequent revisions to the law supplemented it with the additional triggering dates of November 1968 and November 1972, which brought more jurisdictions into coverage . For purposes of the coverage formula, the term "test or device" includes the same four devices prohibited nationally by Section 201--literacy tests, educational or knowledge requirements, proof of good moral character, and requirements that a person be vouched for when voting--and one further device defined in Section 4 (f) (3): in jurisdictions where more than 5% of the citizen voting age population are members of a single language minority group, any practice or requirement by which registration or election materials are provided only in English . The types of jurisdictions that the coverage formula applies to include states and "political subdivisions" of states . Section 14 (c) (2) defines "political subdivision" to mean any county, parish, or "other subdivision of a State which conducts registration for voting ." </P> <P> The 1965 coverage formula included the whole of Alabama, Alaska, Georgia, Louisiana, Mississippi, South Carolina, and Virginia; and some subdivisions (usually counties) in Arizona, Hawaii, Idaho, and North Carolina . The 1968 coverage resulted in the partial coverage of Alaska, Arizona, California, Connecticut, Idaho, Maine, Massachusetts, New Hampshire, New York, and Wyoming . Connecticut, Idaho, Maine, Massachusetts, and Wyoming filed successful "bailout" lawsuits, as also provided by section 4 . The 1972 coverage formula covered the whole of Alaska, Arizona, and Texas, and parts of California, Florida, Michigan, New York, North Carolina, and South Dakota . The special provisions of the Act were due to expire in 1970, and Congress renewed them for another five years . In 1975, the Act's special provisions were extended for another seven years . In 1982, the coverage formula was extended again, this time for 25 years, but no changes were made to the coverage, and in 2006, the coverage formula was again extended for 25 years . </P> <P> Throughout its history, the coverage formula remained controversial because it singled out certain jurisdictions, most of which were in the Deep South . In Shelby County v. Holder (2013), the Supreme Court declared the coverage formula unconstitutional because the criteria used were outdated and thus violated principles of equal state sovereignty and federalism . The other special provisions that are dependent on the coverage formula, such as the Section 5 preclearance requirement, remain valid law . However, without a valid coverage formula, these provisions are unenforceable . </P> <P> Section 5 requires that covered jurisdictions receive federal approval, known as "preclearance", before implementing changes to their election laws . A covered jurisdiction has the burden of proving that the change does not have the purpose or effect of discriminating on the basis of race or language minority status; if the jurisdiction fails to meet this burden, the federal government will deny preclearance and the jurisdiction's change will not go into effect . The Supreme Court broadly interpreted Section 5's scope in Allen v. State Board of Election (1969), holding that any change in a jurisdiction's voting practices, even if minor, must be submitted for preclearance . The Court also held that if a jurisdiction fails to have its voting change precleared, private plaintiffs may sue the jurisdiction in the plaintiff's local district court before a three - judge panel . In these Section 5 "enforcement actions", a court considers whether the jurisdiction made a covered voting change, and if so, whether the change has been precleared . If the jurisdiction improperly failed to obtain preclearance, then the court will order the jurisdiction to obtain preclearance before implementing the change . However, the court may not consider the merits of whether the change should be approved . </P>

Who voted more than 50 pieces of legislation in two years