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August 2.2021 Page 2 of 4 officials to "ignore [minority] interests without fear of political consequences"), citing Rogers v. Lodge, 458 U.S. 613, 623 (1982); White v. Register, 412 U.S. 755, 769 (1973). ]he majority, by virtue of its numerical superiority. will regularly defeat the choices of minority voters." Gingles, at 47. When racially polarized voting occurs, dividing the political unit into single-member districts, or some other appropriate remedy. may facilitate a minority group's ability to elect its preferred representatives. Rogers. at 616. Section 2 of the federal Voting Rights Act ("FVRA"'), 42 U.S.C. § 1973, which Congress enacted in 1965 and amended in 1982. targets. among other things, at-large election schemes. Gingles at 37; see also Boyd & Markman. The 1982 Amendments to the Voting Rights Act: A Legislative History (1983) 40 Wash. & Lee L. Rev. 1347, 1402. Although enforcement of the FVRA was successful in many states, California was an exception. By enacting the CVRA, "[t]he Legislature intended to expand protections against vote dilution over those provided by the federal Voting Rights Act of 1965." Jauregui v. City of Palmdale (2014) 226 Cal. App. 4^ 781, 808. Thus, while the CVRA is similar to the FVRA in several respects, it is also different in several key respects, as the Legislature sought to remedy what it considered "restrictive interpretations given to the federal act." Assem. Corn. on Judiciary, Analysis of Sen. Bill No. 976 (2001-2002 Reg. Sess.) as amended Apr. 9, 2002, p. 2. The California Legislature dispensed with the requirement in Gingles that a minority group demonstrate that it is sufficiently large and geographically compact to constitute a "majority-minority district." Sanchez, at 669. Rather" the CVRA requires only that a plaintiff show the existence of racially polarized voting to establish that an at-large method of election violates the CVRA, not the desirability of any particular remedy. See Cal. Elec. Code § 14028 ("A violation of Section 14027 is established if it is shown that racially polarized voting occurs ...") (emphasis added); also see Assem. Corn. on Judiciary, Analysis of Sen. Bill No. 976 (2001-2002 Reg. Sess.) as amended Apr. 9, 2002, p. 3 ("Thus, this bill puts the voting rights horse (the discrimination issue)back where it sensibly belongs in front of the cart (what type of remedy is appropriate once racially polarized voting has been shown).") To establish a violation of the CVRA, a plaintiff must generally show that "racially polarized voting occurs in elections for members of the governing body of the political subdivision or in elections incorporating other electoral choices by the voters of the political subdivision." Elec. Code § 14028(a). The CVRA specifies the elections that are most probative: "elections in which at least one candidate is a member of a protected class or elections involving ballot measures, or other electoral choices that affect the rights and privileges of members of a protected class." Elec. Code § 14028(a). The CVRA also makes clear that "[e]lections conducted prior to the filing of an action ... are more probative to establish the existence of racially polarized voting than elections conducted after the filing of the action.- Id.