<P> During the Act's early history, Section 3 (c) was little used; no jurisdictions were bailed in until 1975 . Between 1975 and 2013, 18 jurisdictions were bailed in, including 16 local governments and the states of Arkansas and New Mexico . Although the Supreme Court held the Section 4 (b) coverage formula unconstitutional in Shelby County v. Holder (2013), it did not hold Section 3 (c) unconstitutional . Therefore, jurisdictions may continue to be bailed - in and subjected to Section 3 (c) preclearance . In the months following Shelby County, courts began to consider requests by the Attorney General and other plaintiffs to bail in the states of Texas and North Carolina, and in January 2014 a federal court bailed in Evergreen, Alabama . </P> <P> A more narrow bail - in process pertaining to federal observer certification is prescribed in Section 3 (a). Under this provision, a federal court may certify a non-covered jurisdiction to receive federal observers if the court determines that the jurisdiction violated the voting rights guaranteed by the Fourteenth or Fifteenth Amendments . Jurisdictions certified to receive federal observers under Section 3 (a) are not subject to preclearance . </P> <P> Section 4 (b) contains a "coverage formula" that determines which states and local governments may be subjected to the Act's other special provisions (except for the Section 203 (c) bilingual election requirements, which fall under a different formula). Congress intended for the coverage formula to encompass the most pervasively discriminatory jurisdictions . A jurisdiction is covered by the formula if: </P> <Ol> <Li> As of November 1, 1964, 1968, or 1972, the jurisdiction used a "test or device" to restrict the opportunity to register and vote; and </Li> <Li> Less than half of the jurisdiction's eligible citizens were registered to vote on November 1, 1964, 1968, or 1972; or less than half of eligible citizens voted in the presidential election of November 1964, 1968, or 1972 . </Li> </Ol>

All of these were effects of the 1965 voting rights act except