Gomillion v. Lightfoot

Petitioners
C. G. Gomillion, et al.
Respondents
Lightfoot, Mayor of Tuskegee, et al.
Petitioners' Claim
That the state of Alabama re-created the Tuskegee City boundaries to eliminate most African American residents, preventing them from voting in city elections in violation of the Fifteenth Amendment.
Chief Lawyers for Petitioners
Fred D. Gray, Robert L. Carter
Chief Lawyer for Respondents
James J. Carter
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Felix Frankfurter (writing for the Court), John Marshall Harlan II, Potter Stewart, Earl Warren, Charles Evans Whittaker
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
14 November 1960
Decision
Ruling that African American residents had a right to prove in court that theredistricting act was unconstitutional, the Court reversed the two lower courts' dismissal of the complaint.
Significance
Prior to this ruling, the U.S. Supreme Court had been reluctant to interferewith the rights of states to establish political boundaries of their cities.This case, however, demonstrated that states cannot use that power to deprivecitizens of their voting rights guaranteed by the Fifteenth Amendment.
Background
Although the Fifteenth Amendment prohibited voter discrimination based on race, southern states at the time of this case often had requirements that madeit more difficult for blacks to vote. In Alabama they were required to pass literacy tests and present character witnesses from whites. In 1957 the statelegislature, at the request of Tuskegee officials, passed a law that changedthe Tuskegee City boundaries from a square into an irregular shape with 28 sides. This redistricting put all but four or five of the black residents outside the city limits but kept the white voting population intact. Believing that the purpose of this law was to favor white leaders by excluding African Americans from city elections, black residents sued the mayor and city officialsin the U.S. District Court for the Middle District of Alabama. There they argued that the redistricting deprived them of due process and equal protectionunder the Fourteenth Amendment and violated the Fifteenth Amendment ensuringtheir right to vote regardless of race.
The city urged the court to dismiss the case, citing precedence that gave authority for political boundary-setting solely to state legislatures. The courtagreed that it had no power in such cases and dismissed the complaint. WhenAfrican American citizens appealed, the Court of Appeals for the Fifth Circuit upheld the dismissal. Their case then went to the U.S. Supreme Court, whereit was argued in October of 1960.
Supreme Court Reverses Decision
The city relied on past cases of judicial non-interference in reapportionmentto persuade the Supreme Court to dismiss the Gomillion claim as the lower courts had done. The Court, while acknowledging that states did have the powerto act "within the domain of state interest" without interference from the courts, observed that the city had offered no compelling reason for changing its boundaries. The Supreme Court agreed with the petitioners that the obviousresult of the reapportionment had been to deprive African Americans of theirvoting privileges. Since the case thus concerned constitutional rights, the lower courts had been wrong in refusing to hear the case. The Supreme Court voted unanimously to reverse the previous decision. In doing so, however, it did not actually rule that discrimination had occurred, only that there were sufficient grounds for African American residents to pursue their claim of discrimination in court.
In refuting the city's claim, Justice Frankfurter contrasted the present casewith past rulings cited by the city.

In no case involving unequalweight in voting distribution that has come before the Court did the decision sanction a differentiation on racial lines whereby approval was given to .. . withdrawal of the vote solely from colored citizens . . . these considerations lift this controversy out of the so-called "political" arena and into .. . constitutional litigation.

Justice Frankfurter further remarked that the power of states to determine their own political units was stilllimited by the statutes set forth by the U.S. Constitution, specifically, inthis case, the Fifteenth Amendment.
Although concurring with the decision, Justice Whittaker believed that it should have been based on the Fourteenth Amendment rather than the Fifteenth. Observing that the reapportionment act did not actually exclude African American citizens from the voting process, as they were still eligible to vote in their new district, he noted that it did violate the Equal Protection Clause ofthe Fourteenth Amendment through racial segregation.
Impact
This case marked a shift in the Supreme Court's involvement with political redistricting cases. In later cases, the Court ruled that redistricting be doneaccording to population. Although gerrymandering--the process of re-drawingvoting districts to an individual's or group's own advantage in elections--remained an issue after this case, it was determined to be unconstitutional when it clearly discriminated against a particular racial group.
Related Cases

• Hunter v. City of Pittsburgh, 207 U.S. 161 (1907).
  
• Colegrove v. Green, 328 U.S. 549 (1946).
  
• Baker v. Carr, 369 U.S. 186 (1962).
  
• Beer v. United States, 425 U.S. 130 (1976).
  
• Shaw v. Reno, 509 U.S. 630 (1993).

Redistricting
Voting districts within each state are subject to reassessment based upon federal census figures every ten years. In order to maintain an even populationdistribution among districts within each state, a reapportionment is done based upon population increases, decreases, and shifts. Redistricting may involve redrawing the boundaries of congressional districts in conjunction with theU.S. Constitution and Supreme Court cases with the intention that each individual's vote will be worth the same as another's.
Voting districts of equal population density assure that representatives to the U.S. House and state legislatures will be elected based upon an even apportionment of voters. Continual redistricting assures that voting precincts bedivided equally based upon population figures, as much as possible. Care mustbe taken to insure that no boundaries are drawn that knowingly or unintentionally creates districts that discriminate against any group of voters.
Sources
"An Overview of House Reapportionment during the 1990s." http://www.lpitr.state.sc.us/reports/97reapp.htm.
Dictionary of American History, Volume 2. New York: Charles Scribner'sSons, 1976.