Previous 8 / 11 Next

OCTOBER TERM, 1960. Opinion of the Court. 364 U. S. The respondents find another barrier to the trial of this case in Colegrove v. Green, 328 U. S. 549. In that case the Court passed on an Illinois law governing the arrangement of congressional districts within that State. The complaint rested upon the disparity of population between the different districts which rendered the effectiveness of each individual's vote in some districts far less than in others. This disparity came to pass solely through shifts in population between 1901, when Illinois organized its congressional districts, and 1946, when the complaint was lodged.. During this entire period elections were held under the districting scheme devised in 1901. The Court affirmed the dismissal of the complaint on the ground that it presented a subject not meet for adjudication.* The decisive facts in this case, which at this -stage must be taken as proved, are wholly different from the considera,tions found controlling in Colegrove. That case involved a complaint of discriminatory apportionment f congressional districts. The appellants in Colegrove complained only of a dilution of the strength of their votes as a result of legislative inaction over a course of many years. The petitioners here complain that affirmative legislative action deprives them of their votes and the consequent advantages that the ballot affords. When a legislature thus singles out a readily isolated segment of a racial minority for special discriminatory treatment, it violates the Fifteenth Amendment. In no. case involving unequal weight in voting distribution that has come before the Court did the decision sanction a differentiation on racial lines whereby approval was given to unequivocal withdrawa] of the vote solely from colored citizens. Apart from all else, these considerations lift this *Soon after the decision in the Colegrove case, Governor Dwight H. Green of Illinois in his 1947 biennial message to the legislature recommended a reapportionment. The legislature immediately responded, Ill. Sess. Laws 1947, p. 879, and in 1951 redistricted again. Ill. Sess. Laws 1951, p. 1924.

Select target paragraph3

● ● ●

Gomillion v. Lightfoot

Judgment

Question Presented: Whether a state legislature's redefinition of municipal boundaries—designed to exclude African American voters from a city—violates the Fifteenth Amendment, and whether such a legislative act is subject to federal judicial review despite the legislature's general authority to define municipal boundaries.

Alleged Acts: In 1957, the Alabama state legislature enacted Act 140, which redefined the municipal boundaries of the City of Tuskegee, Alabama. The legislation transformed the city's shape "from a square to an uncouth twenty-eight-sided figure," effectively removing from the city virtually all of its African American residents—approximately 400 out of 410 Black voters—while leaving white voters unaffected. The act was "solely concerned" with segregating voters on the basis of race. As a result, African American citizens who had previously lived and voted within the city were stripped of their municipal voting rights, while the city retained its status as the administrative and economic center of the area. A group of African American citizens of Tuskegee, led by Charles Gomillion, filed suit against Mayor P.O. Lightfoot and the City of Tuskegee, challenging the boundary redefinition as unconstitutional.

Procedural history: The state trial court dismissed the complaint, holding that the legislature had plenary authority to redefine municipal boundaries and that the question was non-justiciable. The Supreme Court of Alabama then affirmed the dismissal.

Summary: Gomillion v. Lightfoot was a foundational voting rights decision in which the Supreme Court unanimously held that the Alabama legislature's redefinition of Tuskegee's city boundaries to remove nearly all African American voters violated the Fifteenth Amendment. The case established two critical principles: (1) a state's power to draw or redraw municipal boundaries is not absolute and may be reviewed by federal courts when used as an instrument of racial discrimination in voting; and (2) the Fifteenth Amendment limits not only direct denials of the franchise but also indirect mechanisms—such as boundary manipulation—that achieve the same discriminatory result. The decision is widely regarded as the first case in which the Supreme Court invalidated a racial gerrymander and laid the groundwork for the development of racial gerrymandering jurisprudence that followed in cases such as Shaw v. Reno (1993).

Conclusion: In a unanimous decision, the Supreme Court reversed the Alabama courts and held that Act 140 violated the Fifteenth Amendment. The Court rejected the argument that the legislature's power to define municipal boundaries is absolute and beyond judicial review. When a legislature uses that power as a vehicle for racial discrimination in voting, the act is subject to constitutional scrutiny. The Court held that the Fifteenth Amendment does not merely guarantee the individual right to cast a ballot; it also limits the states' power to draw political boundaries for the purpose of denying or abridging that right on account of race. The Court characterized Act 140 as an act "so extraordinary as to be not even within familiar abuses of gerrymandering," distinguishing it from ordinary political gerrymandering by its expressly racial purpose and effect.

Legal Issue(s)

Electoral Maps and Districting
Voters' Rights

Applicable Law(s): Act 140 of the Alabama Legislature, Fourteenth Amendment, and Fifteenth Amendment of the United States Constitution

Region: Americas

Country: United States of America

Language of Decision

English

Court: Supreme Court

Election Type: General

Date of decision: Nov 14, 1960

Geolocation

Latitude: 38.890591

Longitude: -77.004745

: Geolocation

Link: https://tile.loc.gov/storage-services/service/ll/usrep/usrep364/usrep364339/usrep364339.pdf

Primary Documents

Gomillion v. Lightfoot.pdf
English
Download View

Election Judgments - IFES

Select target paragraph3

Gomillion v. Lightfoot

Primary Documents

Notifications