Mobile v. Bolden
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| Mobile v. Bolden | ||||||||||||
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| Argued March 19, 1979 Reargued October 29, 1979 Decided April 22, 1980 |
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| 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, Jr., Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens |
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| 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 |
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| 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 without racially discriminatory 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.
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[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.
