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Gomillion v. Lightfoot

Supreme Court Reverses Decision

The city relied on past cases of judicial non-interference in reapportionment to persuade the Supreme Court to dismiss the Gomillion claim as the lower courts had done. The Court, while acknowledging that states did have the power to 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 obvious result of the reapportionment had been to deprive African Americans of their voting 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 case with past rulings cited by the city.

In no case involving unequal weight 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 still limited by the statutes set forth by the U.S. Constitution, specifically, in this 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 of the Fourteenth Amendment through racial segregation.

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Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1954 to 1962Gomillion v. Lightfoot - Background, Supreme Court Reverses Decision, Redistricting