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OCTOBER TERM, 1960. Opinion of the Court. 364 U. S. It is difficult to appreciate what stands in the way of adjudging a statute having this inevitable effect invalid in light of the principles by which this Court must judge, and uniformly has judged, statutes that, howsoever speciously defined, obviously discriminate against colored citizens. "The [Fifteenth] Amendment nullifies sophisticated as well as simple-minded modes of discrimination." Lane v. Wilson, 307 U. S. 268, 275. The complaint amply alleges a claim of racial discrimination. Against this claim the respondents have never suggested, either in their brief or in oral argument, any countervailing municipal function which Act 140 is designed to serve. The respondents invoke generalities expressing the State's unrestricted power-unlimited, that is, by the United States Constitution-to establish, destroy, or reorganize by contraction or expansion its political subdivisions, to wit, cities, counties, and other local units. We freely recognize the breadth and importance of this aspect of the State's political power. To exalt this power into an absolute is to misconceive the reach and rule of this Court's decisions in the leading case of Hunter v. Pittsburgh,207 U. S. 161, and related cases relied upon by respondents. I The Hunter case involved a claim by citizens of Allegheny, Pennsylvania, that the General Assembly of that State could not direct a consolidation of their city and Pittsburgh over the objection of a majority of the Allegheny voters. It was alleged that while Allegheny already had made numerous civic improvements, Pittsburgh was only then planning to undertake such improvements, and that the annexation would therefore greatly increase the tax burden on Allegheny residents. All that the case held was (1) that there is no implied contract between a city and its residents that their taxes will be spent solely for the benefit of that city, and (2) that a citizen of one municipality is not de-

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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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