After the passage of the Voting Rights Act of 1965, the first four African American legislators were elected to the Arkansas General Assembly in eighty years. In 1982 redistricting, one further house seat was added, filled by Irma Hunter Brown, the first African American woman in the General Assembly. A lawsuit in 1988 added another house seat filled by Ben McGee from Crittenden County, the first African American elected outside of Pulaski and Jefferson counties in the twentieth century. A court decision in 1989 ordered the creation of two new majority-black senate districts and seven new majority-black house districts. Arkansas was also placed under the preclearance requirements of the Voting Rights Act, earning it the dubious distinction of being only one of two states, along with New Mexico, to ever have been “bailed-in” to the Voting Rights Act.