City of Mobile v. Bolden
| Mobile v. Bolden | |
|---|---|
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| Argued March 19, 1979 Reargued October 29, 1979 Decided April 22, 1980 |
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| Full case name | City of Mobile, Alabama, et al. v. Bolden, et al. |
| Citations | 446 U.S. 55 (more)
100 S. Ct. 1490; 64 L. Ed. 2d 47; 1980 U.S. LEXIS 121
|
| Prior history | Judgment for plaintiffs, 423 F. Supp. 384; affirmed 571 F.2d 238, probable jurisdiction noted, 439 U.S. 815 |
| Holding | |
| Facially neutral electoral districting is constitutional, even if the at-large elections dilute the voting strength of black citizens. | |
| Court membership | |
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| Case opinions | |
| Plurality | Stewart, joined by Burger, Powell, Rehnquist |
| Concurrence | Blackmun |
| Concurrence | Stevens |
| Dissent | Brennan |
| Dissent | White |
| Dissent | Marshall |
| Laws applied | |
| U.S. Const. amends. XIV, XV; 79 Stat. 437, as amended, 42 U.S.C. 1973 | |
Mobile v. Bolden, 446 U.S. 55 (1980), was a case in which the Supreme Court of the United States held that disproportionate effects alone—i.e. absent purposeful discrimination—are insufficient to establish a claim of racial discrimination affecting voting.
In Gomillion v. Lightfoot (1960), which challenged new city boundaries that excluded virtually all black voters from Tuskegee, Alabama, the court had held that creating electoral districts which disenfranchised blacks violated the Fifteenth Amendment. It did not as readily distinguish between intent and results as it would in Mobile.
In 1911 the state legislature enacted a three-member city commission form of government for the city of Mobile, Alabama. With members elected at-large, the commission exercised all legislative, executive and administrative power. Since the entire city voted for each Commissioner, the white majority generally controlled the elections. At the time both African Americans and poor whites were effectively disenfranchised by practices of the 1901 state constitution.
After African Americans regained the power to register and vote through passage of the Voting Rights Act of 1965, they were discouraged by being unable to elect candidates of their choice to the city commission. The financial and strategic demands for citywide elections made it difficult for them to enter the race, and the white majority tended to support white candidates, particularly as conservatives moved into the Republican Party. African Americans supported Democratic Party candidates.
In the late 1970s, a class-action suit was filed on behalf of all the city's black residents against the city and all three Commissioners. Their complaint alleged that the city's electoral system violated the Fourteenth and Fifteenth amendments 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. The form of city government was subsequently changed. (See below.)
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