Gomillion v. Lightfoot

Supreme Court of United States
364 U.S. 339 (1960)

ELI5:

Rule of Law:

A state violates the Fifteenth Amendment when it purposefully alters a municipality's boundaries to remove voters of a particular race, thereby depriving them of their right to vote in municipal elections.

Facts:

Prior to 1957, the City of Tuskegee, Alabama, was geographically shaped like a square.
Charles Gomillion and other Negro citizens were residents and registered voters within the square-shaped City of Tuskegee.
In 1957, the Alabama Legislature passed Local Act No. 140.
Act 140 redefined the boundaries of Tuskegee, changing its shape from a simple square to an irregular twenty-eight-sided figure.
The practical effect of this boundary change was to remove from the city all but four or five of its approximately 400 Negro voters.
The redefinition of the city's boundaries did not remove a single white voter or resident.

Procedural Posture:

Negro citizens of Tuskegee (Gomillion et al.) sued the Mayor and other officials of the city (Lightfoot et al.) in the U.S. District Court for the Middle District of Alabama.
The respondents (Lightfoot et al.) filed a motion to dismiss the action for failure to state a claim upon which relief could be granted.
The District Court granted the motion to dismiss, stating it had no power to change boundaries fixed by a state legislature.
The petitioners (Gomillion et al.) appealed this decision to the U.S. Court of Appeals for the Fifth Circuit.
The Court of Appeals affirmed the District Court's dismissal of the case.
The U.S. Supreme Court granted certiorari to review the judgment of the Court of Appeals.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state law that alters the boundaries of a municipality to remove nearly all of its Black voters, while not removing any white voters, violate the Fifteenth Amendment?

Opinions:

Majority - Mr. Justice Frankfurter

Yes, a state law that alters municipal boundaries for the purpose of disenfranchising citizens on account of their race violates the Fifteenth Amendment. While states possess broad power over their political subdivisions, this power is not absolute and must yield to the limitations imposed by the United States Constitution. The allegations, if proven, would establish that Act 140 was not a legitimate geographic redistricting measure but a device to disenfranchise Negro citizens by fencing them out of the city. The Court distinguished this case from precedents like Hunter v. Pittsburgh, which affirmed broad state power over municipalities in economic matters, clarifying that such power cannot be used as an instrument for circumventing a federally protected right. This case is also distinct from the 'political question' doctrine of Colegrove v. Green because it involves affirmative state action to single out and discriminate against a racial minority, rather than mere legislative inaction or vote dilution.

Concurring - Mr. Justice Whittaker

The judgment is correct, but it should be based on the Equal Protection Clause of the Fourteenth Amendment, not the Fifteenth Amendment. It is doubtful that the petitioners' 'right to vote' was abridged in the Fifteenth Amendment sense, as they could still vote in the new political division where they resided. However, the state's act of 'fencing Negro citizens out of' the city constitutes an unlawful segregation of races. This clear racial segregation, akin to the issues in Brown v. Board of Education, is a violation of the Equal Protection Clause.

Analysis:

This landmark decision established that federal courts have the authority to invalidate state redistricting and boundary laws when they are used as a tool for racial discrimination. It created a significant exception to the general principle of broad state authority over political subdivisions and limited the applicability of the political question doctrine in voting rights cases. The ruling in Gomillion opened the door for federal judicial review of gerrymandering, paving the way for subsequent reapportionment cases like Baker v. Carr and reinforcing the protections of the Fifteenth Amendment against sophisticated forms of disenfranchisement.

Gunnerbot

AI-powered case assistant

Loaded: Gomillion v. Lightfoot (1960)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature