Mobile v. Bolden

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Mobile v. Bolden
Supreme Court of the United States
Argued March 19, 1979 Reargued October 29, 1979 Decided April 22, 1980
Full case name: City of Mobile, Alabama, et al. v. Bolden, et al. Citations: 446 U.S. 55; 100 S. Ct. 1490; 64 L. Ed. 2d 47; 1980 U.S. LEXIS 121 Prior history: Judgement 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
Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens
Case opinions
Plurality by: Stewart Joined by: Burger, Powell, Rehnquist Concurrence by: Blackmun Concurrence by: Stevens Dissent by: Brennan Dissent by: White Dissent by: 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)^[1], was a case in which the Supreme Court of the United States held that electoral districts must be drawn with racially discriminatory effect and intent to warrant constitutional protection. In Gomillion v. Lightfoot, the court had held that creating electoral districts which disenfranchised blacks violated the Fifteenth Amendment, but it did not as readily distinguish between effect and intent as it would in Mobile.

Contents 1 Facts 2 Issue 3 Result 4 Analysis 5 References

[edit] Facts

The city of Mobile, Alabama 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, 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 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.

[edit] Issue

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

[edit] 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.

[edit] Analysis

The case somewhat limited the court's previous holding in Gomillion.

[edit] References

1. ^ 446 U.S. 55 (Full text of the opinion courtesy of Findlaw.com)