Gomillion v. Lightfoot
Encyclopedia
Gomillion v. Lightfoot, 364 U.S. 339
(1960), was a United States Supreme Court
decision that found an electoral district created to disenfranchise blacks violated the Fifteenth Amendment
.
. It had previously been a square but the legislature redrew it as a 28 sided figure, excluding all but a handful of potential African-American votes. Justice Frankfurter issued the opinion of the Court, which held that the Act did violate the provision of the 15th Amendment prohibiting states from denying anyone their right to vote on account of race, color, or previous condition of servitude. As he said in his concurring opinion, Justice Whitaker would have struck it down under the equal protection clause
, which is what the Court later did in Baker v. Carr
.
Just because someone has been redistricted to vote in another district does not automatically mean his rights have been denied. It is not a right to vote in a particular jurisdiction. But in this case, completely fencing Negro citizens out a district is an unlawful segregation of black citizens and a clear violation of the Equal Protection Clause.
, the court limited its holding in Gomillion so that racially discriminatory effect and intent would be necessary to prompt intervention by federal courts for violations of Section 2 of the Voting Rights Act.
However, Congress effectively negated Bolden in 1982 when it amended Section 2 of the Voting Rights Act, 42 U.S.C. § 1973. Congress' amendments returned the law to the pre-Bolden interpretation, under which violations of Section 2 did not require a showing of racially discriminatory intent.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1960), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that found an electoral district created to disenfranchise blacks violated the Fifteenth Amendment
Fifteenth Amendment to the United States Constitution
The Fifteenth Amendment to the United States Constitution prohibits each government in the United States from denying a citizen the right to vote based on that citizen's "race, color, or previous condition of servitude"...
.
Decision
In this landmark voting rights case, the Supreme Court was faced with the question of whether or not Act 140 of the Alabama legislature violated the Fifteenth Amendment. Alabama passed Act 140 in 1957, which changed the boundaries of the city of Tuskegee, AlabamaTuskegee, Alabama
Tuskegee is a city in Macon County, Alabama, United States. At the 2000 census the population was 11,846 and is designated a Micropolitan Statistical Area. Tuskegee has been an important site in various stages of African American history....
. It had previously been a square but the legislature redrew it as a 28 sided figure, excluding all but a handful of potential African-American votes. Justice Frankfurter issued the opinion of the Court, which held that the Act did violate the provision of the 15th Amendment prohibiting states from denying anyone their right to vote on account of race, color, or previous condition of servitude. As he said in his concurring opinion, Justice Whitaker would have struck it down under the equal protection clause
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
, which is what the Court later did in Baker v. Carr
Baker v. Carr
Baker v. Carr, , was a landmark United States Supreme Court case that retreated from the Court's political question doctrine, deciding that redistricting issues present justiciable questions, thus enabling federal courts to intervene in and to decide reapportionment cases...
.
Whittaker's Concurrence
This case should be examined under the Equal Protection Clause, not the 15th amendment.Just because someone has been redistricted to vote in another district does not automatically mean his rights have been denied. It is not a right to vote in a particular jurisdiction. But in this case, completely fencing Negro citizens out a district is an unlawful segregation of black citizens and a clear violation of the Equal Protection Clause.
Subsequent history
In the 1980 case Mobile v. BoldenMobile v. Bolden
Mobile v. Bolden, 446 U.S. 55 , was a case in which the Supreme Court of the United States held that electoral districts must be drawn without racially discriminatory intent to warrant constitutional protection. In Gomillion v...
, the court limited its holding in Gomillion so that racially discriminatory effect and intent would be necessary to prompt intervention by federal courts for violations of Section 2 of the Voting Rights Act.
However, Congress effectively negated Bolden in 1982 when it amended Section 2 of the Voting Rights Act, 42 U.S.C. § 1973. Congress' amendments returned the law to the pre-Bolden interpretation, under which violations of Section 2 did not require a showing of racially discriminatory intent.
See also
- GerrymanderingGerrymanderingIn the process of setting electoral districts, gerrymandering is a practice that attempts to establish a political advantage for a particular party or group by manipulating geographic boundaries to create partisan, incumbent-protected districts...
- Hunt v. CromartieHunt v. CromartieHunt v. Cromartie, 526 U.S. 541 , was a United States Supreme Court case regarding the contentious 12th district of North Carolina. In an earlier case, Shaw v. Reno, 517 U.S...
- Full text of the decision courtesy of Findlaw.com
- List of United States Supreme Court cases, volume 364
- Civil Rights CasesCivil Rights CasesThe Civil Rights Cases, 109 U.S. 3 , were a group of five similar cases consolidated into one issue for the United States Supreme Court to review...
- Brown v. Board of EducationBrown v. Board of EducationBrown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
of Topeka - Timeline of the American Civil Rights MovementTimeline of the American Civil Rights MovementThis is a timeline of African-American Civil Rights Movement.-Pre-17th century:1565*unknown – The colony of St...