Gomillion v. Lightfoot

Gomillion v. Lightfoot

Gomillion v. Lightfoot was an important 1960 Supreme Court verdict concerning the rights of African-Americans to vote in elections. The case had its origins in a 1957 piece of legislation passed by the Legislature of Alabama, known as Local Act No. 140. This act changed the boundaries of the city of Tuskegee from a four-sided figure to a 28-sided figure. As a result of this change of the city's boundaries, 400 African-American voters were excluded from the district that they were previously part of except for four or five. Meanwhile, the white voters in the area were left intact.

In response, a group of African-American citizens filed suit against the mayor of Tuskegee in Federal District Court, seeking a judgment that this legislation was unconstitutional. However, the District Court declined to rule, stating that it had no jurisdiction over Alabama legislation governing the state. The African-American citizens then appealed to the US Supreme Court, seeking the same kind of ruling.

In the plaintiffs' filing in Gomillion v. Lightfoot, they argued that this legislative action was taken for the sole purpose of denying African-Americans the right to vote in their own district. They argued that this kind of action was therefore a violation of the 15th Amendment. In response, the city argued that the passage of this kind of legislation was within the authority of the state, which is granted unlimited power over the creation, consolidation and destruction of voting districts.

In ruling against the city in Gomillion v. Lightfoot, the Supreme Court justices noted that the city had never demonstrated any kind of municipal function or benefit that would be created by the creation of this 28-sided district. Therefore, since the sole purpose of the creation of this district was to deny African-Americans the right to vote on the basis of their race, the Supreme Court ruled that it was a violation of the Fifteenth Amendment, which is greater than the rights of states to reorganize their voting districts.

In concurring with the unanimous opinion in Gomillion v. Lightfoot, Supreme Court Justice Whittaker argued that while the ruling was correct, the reasoning was faulty. Instead, he argued that the constitutional violation in question was of the Equal Protection Clause of the 14th Amendment rather than of the 15th Amendment's prohibition of racial discrimination.

The ruling in Gomillion v. Lightfoot was reexamined in the 1980 case of Mobile v. Bolden. In this case, African-American citizens of Mobile claimed that the practice of electing three members of a City Commission from the city as a whole rather than from three separate districts made it difficult for the African-American community to elect a representative of its choice. The Supreme Court ruled in favor of the city, since it could not be proven that this election process, though discriminatory in effect, was undertaken with the specific intent of disenfranchising African-Americans. This somewhat reduced the authority of the Supreme Court to intervene in such instances.