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GOMILLION v. LIGHTFOOT. 339 Opinion of the Court. controversy out of the so-called "political" arena and into the conventional sphere of constitutional litigation. In sum, as Mr. Justice Holmes remarked, when dealing with a related situation, in Nixon v. Herndon, 273 U. S. 536, 540, "Of course the petition concerns political action," but "The objection that the subject matter of the suit is political is little more than a play upon words." A statute which is alleged to have worked unconstitutional deprivations of petitioners' rights is not immune to attack simply because the mechanism employed by the legislature is a redefinition of municipal boundaries. According to the allegations here made, the Alabama Legislature has not merely redrawn the Tuskegee city limits with incidental inconvenience to the petitioners; it is more accurate to say that it has deprived the petitioners of the municipal franchise and consequent rights and to that end it has incidentally changed-the city's boundaries. While in form this is merely an act redefining metes and bounds, if tlhe allegations ate established, the inescapable human effect of this essay in geometry and geography is to despoil colored citizens, and only colored citizens, of their theretofore enjoyed voting rights. That was not Colegrove v. Green. When a State'exercises power wholly within the domain of state interest, it is insulated, from federal judicial review. But such insulation is not carried over when state power is used as an instrument for circumventing a federally protected right. This principle has had many applications. It has long been recognized in cases which have prohibited a State from exploiting a power acknowledged to be absolute in an isolated context to justify the imposition of an "unconstitutional condition." What the Court has said in those cases is equally applicable here, viz., that "Acts generally lawful may become unlawful when done to accomplish an unlawful end, United States v. Reading Co., 226 U. S.324, 357, and a constitutional power cannot be used by way of condition to attain an

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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

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Gomillion v. Lightfoot.pdf
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Gomillion v. Lightfoot

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