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GOMILLION v. LIGHTFOOT. 339 Opinion of the Court. convened and elected legislative body, acting for the people in the State of Alabama." 167 F. Supp. 405, 410. On appeal, the Court of Appeals for the Fifth Circuit, affirmed the judgment, one judge dissenting. 270 F. 2d 594. We brought the case here since serious questions were raised concerning the power of a State over its municipalities in relation to the Fourteenth and Fifteenth Amendments. • 362 U. S. 916. At this stage of the litigation we are not concerned with the truth of the allegations, that is, the ability of petitioners to sustain their allegations by proof. The sole question is whether the allegations entitle them to make good on their claim that they are being denied rights under the United States Constitution. The complaint, charging that Act 140 is a device to disenfranchise Negro citizens, alleges the following facts: Prior to Act 140 the City of Tuskegee was square in shape; the Act transformed it into a strangely irregular twenty-eight-sided figure as indicated in the diagram appended to this opinion. The essential inevitable effect of this redefinition of Tuskegee's boundaries is to remove from the city all save only four or five of its 400 Negro voters while not removing a single white voter or resident. The result of the Act isto deprive the Negro petitioners discriminatorily of the benefits of residence in Tuskegee, including, inter alia, the right to vote in municipal elections. These allegations, if proven, would abundantly establish that Act 140 was not an ordinary geographic redistricting measure even within familiar abuses of- gerrymandering. If these allegations upon a trial remained uncontradicted or unqualified, the conclusion would be irresistible, tantamount for all practical purposes to a mathematical demonstration, that the legislation is solely concerned with segregating white and colored voters by fencing Negro citizens out of town so as to deprive them of their pre-existing municipal.vote.

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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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