Gomillion v. Lightfoot

1960-11-14

Headline: Court reverses lower-court dismissals and allows challenge to Alabama law that reshaped Tuskegee’s borders to remove nearly all Black voters, blocking state use of boundary changes to disenfranchise residents.

Holding: The Court held that allegations that Alabama redrew Tuskegee’s city limits to remove almost all Black voters state a valid constitutional claim under the Fifteenth Amendment and must be allowed to proceed to trial.

Real World Impact:

Allows affected Black residents to have their boundary-based voting claims heard at trial.
Limits state power to use redrawn city borders to remove voters of a single race.
Signals courts will review municipal boundary changes alleged to be racially motivated.

Topics: voting rights, racial discrimination, city boundaries, state power

Summary

Background

Black residents of Tuskegee, Alabama sued after the State passed Act No. 140 in 1957, which changed the city from a square into a 28-sided shape. The complaint says the new boundary removed all but four or five of about 400 Black voters while taking no white voters out, and so deprived those residents of the benefits of city residence, including the municipal vote. The federal district court and the court of appeals dismissed the case, and the petitioners asked the Supreme Court to decide whether their allegations could be heard.

Reasoning

The Court considered whether a State’s power to redraw city lines is absolute when a boundary change appears aimed at taking away the vote of a racial group. The majority said that if the petitioners’ factual allegations are true, the map change would amount to deliberate racial disenfranchisement and thus raise a constitutional claim under the Fifteenth Amendment (which forbids denying the vote because of race). The Court stressed that state authority to change municipal borders does not let a legislature accomplish an unconstitutional result.

Real world impact

The decision sends the case back so the petitioners can prove their allegations at trial rather than be blocked by a dismissal. It means that legislatures cannot hide racially discriminatory removal of voters behind routine-sounding changes to municipal boundaries. This ruling at this stage is not a final finding on guilt or innocence; it simply allows the claim to be tried.

Dissents or concurrances

A concurring Justice agreed with the result but preferred to rest the decision on the Fourteenth Amendment’s guarantee of equal protection rather than the Fifteenth Amendment, saying the map amounted to unlawful racial segregation.