Mobile v. Bolden, 446 U.S. 55

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...

 (1980), was a case in which the Supreme Court of the United States

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...

 held that electoral districts must be drawn without racially discriminatory intent to warrant constitutional protection. In Gomillion v. Lightfoot

Gomillion v. Lightfoot

Gomillion v. Lightfoot, 364 U.S. 339 , was a United States Supreme Court decision that found an electoral district created to disenfranchise blacks violated the Fifteenth Amendment.- Decision :...

, the court had held that creating electoral districts which disenfranchised 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"...

, but it did not as readily distinguish between effect and intent as it would in Mobile.

Facts

The city of Mobile, Alabama

Mobile, Alabama

Mobile is the third most populous city in the Southern US state of Alabama and is the county seat of Mobile County. It is located on the Mobile River and the central Gulf Coast of the United States. The population within the city limits was 195,111 during the 2010 census. It is the largest...

 governs itself by a City Commission that exercises all legislative, executive and administrative power. The three members of the Commission are elected from the city at-large

At-Large

At-large is a designation for representative members of a governing body who are elected or appointed to represent the whole membership of the body , rather than a subset of that membership...

, instead of from three separate single-member districts. Since each Commissioner is elected from the entire city, it is more difficult for a geographically concentrated constituency, such as blacks, to elect someone sympathetic to their interests. A class-action suit was filed on behalf of all the city's black residents against the city itself and all three Commissioners. Their complaint alleged that the city's electoral system violated the Fourteenth

Fourteenth Amendment to the United States Constitution

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...

 and 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"...

s and Section 2 of the Voting Rights Act of 1965, among other laws. The District Court found for the city's black residents and the Court of Appeals affirmed.

Issue

The Supreme Court agreed to decide whether this at-large system violated Amendments Fourteen or Fifteen or the Voting Rights Act.

Result

The court ruled 6-3 for the city of Mobile. In his plurality opinion, Stewart concluded that the relevant language of the Voting Rights Act paralleled that of the Fifteenth Amendment. Stewart dismissed both the Fifteenth and Fourteenth Amendment claims, deciding that both Amendments required proof of racially-motivated intent. Stevens applied a slightly different standard in his concurring opinion but came to the same result about the Constitutionality of Mobile's system.