Mobile v. Bolden
| Mobile v. Bolden | ||||||
|---|---|---|---|---|---|---|
 | ||||||
| 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 (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 | ||||||
| ||||||
| 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 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.
Background
The city of Mobile, Alabama governed itself by a City Commission that exercised all legislative, executive and administrative power. The three members of the Commission were elected from the city at-large, instead of from three separate single-member districts. Since each Commissioner was elected from the entire city, it was 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. The form of city government was subsequently changed.
The Supreme Court agreed to decide whether this at-large system violated Amendments Fourteen or Fifteen or the Voting Rights Act.
Opinion of the Court
The court ruled 6-3 for the city of Mobile. In his plurality opinion, Justice Stewart concluded that the relevant language of the Voting Rights Act paralleled that of the Fifteenth Amendment. Stewart dismissed the Fifteenth Amendment claim, citing "the District Court's findings of fact, unquestioned on appeal, [that] make clear that Negroes register and vote in Mobile 'without hindrance,' and that there are no official obstacles in the way of Negroes who wish to become candidates for election to the Commission.".[1] He also rejected the Fourteenth Amendment claims, holding that "action by a State that is racially neutral on its face violates the Fifteenth Amendment only if motivated by a discriminatory purpose."[2] Justice Stevens applied a slightly different standard in his concurring opinion but came to the same result about the Constitutionality of Mobile's system.
The case somewhat limited the court's previous holding in Gomillion.
References
446 U.S. 55 (Full text of the opinion courtesy of Findlaw.com)