Gomillion v. Lightfoot

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Gomillion v. Lightfoot
Seal of the United States Supreme Court.svg
Argued October 18–19, 1960
Decided November 14, 1960
Full case nameGomillion et al. v. Lightfoot, Mayor of Tuskegee, et al.
Citations364 U.S. 339 (more)
364 U.S. 339; 81 S. Ct. 125; 5 L. Ed. 2d 110; 1960 U.S. LEXIS 189
Prior historyCertiorari to the United States Court of Appeals for the Fifth Circuit
Holding
Electoral district boundaries drawn only to disenfranchise blacks violate the Fifteenth Amendment.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Tom C. Clark
John M. Harlan II · William J. Brennan, Jr.
Charles E. Whittaker · Potter Stewart
Case opinions
MajorityFrankfurter, joined by Warren, Black, Douglas, Clark, Harlan, Brennan, Stewart
ConcurrenceWhittaker
Laws applied
U.S. Const. amend. XV

Gomillion v. Lightfoot, 364 U.S. 339 (1960)[1], was a United States Supreme Court decision in which the Court ruled the redrawing of the city's electoral district boundaries to prevent blacks from voting was unconstitutional.[1] The unanimous Court held that it violated the Fifteenth Amendment to the United States Constitution.[2] This case was one of several that led to the passage of the Voting Rights Act of 1965.[1]

Background[change | change source]

In 1957, the Alabama state legislature passed Act number 140 that changed the borders of the city of Tuskegee's electoral district.[3] It changed the square boundary of Tuskegee to an irregular 28-sided figure that eliminated all but a few of the city's 400 black voters but did not eliminate any white voters.[4] It had the effect of keeping African-American citizens from voting. The petitioners Charles A. Gomillion and other black former residents of Tuskegee brought the suit against the Mayor of Tuskegee, Philip M. Lightfoot.[3] They wanted the law ruled unconstitutional under the Fifteenth Amendment.[3] They also wanted an order that prevented the city from enforcing the Act.[3]

Fifth District Court ruling[change | change source]

The District Court dismissed the case on the grounds it did not have the authority to invalidate an Act passed by the state legislature.[4] The court ruled:

"In the absence of any racial or class discrimination on the face of the statute, the courts will not hold an act, which decreases the area of a municipality by changing its boundaries, to be invalid under the Fourteenth and Fifteenth Amendments to the United States Constitution – even though the enactment of the statute was for the purpose of removing Negroes from the city and depriving them of the privileges and benefits of municipal citizenship, including the right to vote in city elections."[5]

Supreme Court ruling[change | change source]

On 14 November 1960, the Supreme Court dismissed the ruling by the lower courts and ruled the Alabama redistricting act was unconstitutional.[6] Justice Felix Frankfurter wrote the majority opinion.[2] He admitted that when states exercise power "wholly within the domain of state interest" they are generally protected from judicial review.[2] But Alabama's representatives were not able to identify "any countervailing municipal function" that this act could serve.[2] It was clear the irregular shaped district had only one purpose, namely, to prevent blacks from any participation in the political system of Tuskegee.[2]

Significance[change | change source]

This case marked a change in the Supreme Court's involvement in political redistricting.[6] Up to this point the Court had shown it was reluctant to interfere with the States when establishing political boundaries of their cities.[6] However, this case served to show that states cannot deprive citizens of their voting rights which are protected by the Fifteenth Amendment.[6] Although the practice of gerrymandering remained an issue after this case, the Court determined it was unconstitutional when it clearly discriminated against any particular racial group.[6]

References[change | change source]

  1. 1.0 1.1 Allen Mendenhall, Auburn University. "Gomillion v. Lightfoot". The Encyclopedia of Alabama. Retrieved 15 April 2016.
  2. 2.0 2.1 2.2 2.3 2.4 "Gomillion v. Lightfoot". IIT Chicago-Kent College of Law. Retrieved 15 April 2016.
  3. 3.0 3.1 3.2 3.3 "Gomillion v. Lightfoot". ProCon.org. Retrieved 15 April 2016.
  4. 4.0 4.1 "US Supreme Court: Gomillion v. Lightfoot, 364 U.S. 339 (1960)". Justia. Retrieved 15 April 2016.
  5. "Gomillion v. Lightfoot 270 F.2d 594 (5th Cir.) U.S. App. LEXIS 3363 (1959)" (PDF). Stetson University College of Law. Retrieved 15 April 2016.
  6. 6.0 6.1 6.2 6.3 6.4 "Gomillion v. Lightfoot - Background, Supreme Court Reverses Decision, Redistricting". Law Library - American Law and Legal Information. Retrieved 15 April 2016.