Charleston County, South Carolina v. United States

How later courts describe this case

• construing the term “previously” in §§ 2244(b)(2)(A) and 2244(b)(2)(B)(i), and holding that “constitutional rules that were established at the time of the applicant’s last [pre-filing authorization] motion were not ‘previously unavailable’ ”
• satisfying the three Gingles preconditions is not enough; a plaintiff must show that under the totality of the circumstances the electoral scheme violates Section 2