211 Moreover one could argue that there would be a violation of Section 2 even

211 moreover one could argue that there would be a

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211 Moreover, one could argue that there would be a violation of Section 2 even if all council members were elected at the same time. If it takes longer for minority members to establish the contacts needed to be as effective as white members, term limits would still abridge the voters' ability to participate in the political process. See Neal R. Pierce, Minorities Slowly Gain State Offices, 23 NAT'L J. 33, 33 (1991) ("Minorities start as outsiders; they have to work harder than whites to become insiders."). 2359
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2360 UNIVERSITY OF PENNSYLVANIA LAW REVIEW [Vol. 141: 2311 B. An Examination of Congressional Term Limits 1. The Effect of Term Limits on Minority Seniority Minorities have accomplished much in the area of electoral success since the Voting Rights Act was enacted in 1965.212 Not only have they elected African-Americans and other minorities to Congress, but also, due to the seniority system, these representatives have risen to key leadership positions in Congress. Although not intended as such when originally enacted, the seniority system removes the possibility of discriminatory barriers that would keep minority members of Congress from congressional leadership. 2 13 Two high visibility examples of the gains that minorities have made as a result of seniority are former Representative William Gray, a Pennsylvania Democrat, and Representative Ronald Dellums, a California Democrat. During his tenure in office, Gray served on the House Appropri- ations Committee, a body "which controls federal purse strings." 2 14 Gray resigned from Congress in September of 1991 212 See supra note 165 and accompanying text. 213 See MEZEY, supra note 27, at 70. Mezey states: [A]t the end of [the nineteenth] century and the beginning of the twentieth, the forces of populism and progressivism that had attacked party organiza- tions in general turned their attention to the task of dismantling many of the prerogatives of the congressional party leaders. Most important was the formalizing after 1911 of the seniority system, by which committee chairmanships were automatically awarded to the majority party member with the longest tenure on the committee. This development placed the committee chairs completely beyond the reach of party leaders; if the chairs were reelected, they would retain their committee posts regardless of the wishes of the leadership. Id. (emphasis added). 214 Camire & Bumstedad, supra note 100. Gray also served as House majority whip (a position which made him the highest ranking African-American in Congress and placed him third in line to become speaker of the House) and chairman of the Budget Committee. See Elaine S. Povich, Key Black LeaderMay Quit House, CHI. TRIB., June 19, 1991, § 1, at 5. Although these two powerful posts are filled through election by the House membership, Gray could not have reached them without having a continuing relationship with his colleagues; a relationship allowing him to overcome any possible racial or regional distrust. See, e.g., Christopher Matthews, House Democrats: You Can't Tell The Players Without a Program, WASH. POST, May 28, 1989, at B7. Mr.
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