Gomillion v. Lightfoot
The Supreme Court ruled that Black residents of Tuskegee, Alabama could sue over a state law that redrew the city's boundaries from a square into a 28-sided shape, removing all but a handful of the city's 400 Black voters while removing no white voters.
The Court held that a state's broad power to redraw municipal boundaries cannot be used to strip citizens of their voting rights because of race, reversing lower courts that had dismissed the case as outside judicial review.
“While in form this is merely an act redefining metes and bounds, if the allegations are established, the inescapable human effect of this essay in geometry and geography is to despoil colored citizens, and only colored citizens, of their theretofore enjoyed voting rights.”
The Court's core reasoning that a boundary-line change with a racially discriminatory effect cannot escape constitutional scrutiny.
How it got here: A federal district court dismissed the suit for lack of jurisdiction and failure to state a claim; the Fifth Circuit affirmed over one dissent, and the Supreme Court agreed to review it.
The Case in Depth
What happened
Alabama's legislature passed a 1957 law redrawing Tuskegee's city limits from a square into an oddly shaped 28-sided figure. Black residents of Tuskegee alleged the redrawing removed all but four or five of the city's roughly 400 Black voters while removing no white residents, effectively ending their ability to vote in city elections. They sued Tuskegee's mayor and Macon County officials, seeking a declaration that the law was unconstitutional and an injunction against its enforcement.
The question before the Court
Could Alabama redraw a city's boundaries so that almost every Black voter was pushed outside city limits while no white voter was removed?
Why it matters
The ruling meant that state and local governments could not use boundary-line changes, map-drawing, or other seemingly neutral administrative tools to strip a racial group of the right to vote. It gave Black voters and others a path into federal court to challenge redistricting and annexation schemes that function as racial disenfranchisement, even though states normally have wide latitude over their own political subdivisions.
What changes now
The case is sent back so the Black petitioners can attempt to prove at trial that Act 140 was in fact designed to strip them of their voting rights because of race. The Supreme Court did not decide whether the allegations were true — only that, if proven, they would state a valid constitutional claim rather than being immune from review as a matter of state municipal power.
What this does not decide
The Court did not decide whether Act 140 actually was enacted for a discriminatory purpose — only that the allegations, if proven, stated a valid constitutional claim that could not be dismissed outright. The factual question of the law's purpose and effect was left for trial.
Concurrences and dissents
Concurrence — Justice Whittaker
Justice Whittaker agreed the case should go to trial but disagreed with resting the decision on the Fifteenth Amendment. He argued the right to vote guaranteed by that Amendment is only the same right enjoyed by others in one's assigned political division, so redistricting someone into a new division does not itself violate it. He would instead ground the ruling on the Equal Protection Clause, reasoning that using redistricting to segregate voters by race is unlawful racial segregation.
Concurrence — Justice Douglas
Justice Douglas joined the Court's opinion in full but noted separately that he continues to adhere to his earlier dissenting views in Colegrove v. Green and South v. Peters, cases involving different voting-related claims the majority distinguished from this one.
How the Court got there
The legal reasoning, step by step
- The Court took as true, at this pleading stage, the complaint's allegations that the boundary change removed nearly all Black voters from the city while removing no white voters, since the case had been dismissed before any trial on the facts.
- The Court rejected the argument that a state's broad authority over its municipal boundaries is unlimited, explaining that earlier cases recognizing that power, such as Hunter v. Pittsburgh, only held that boundary changes are free from contract-based or due-process challenges to tax burdens — not that boundary power is immune from every constitutional limit.
- The Court distinguished this case from Colegrove v. Green, a earlier ruling that had treated a claim of vote-dilution from outdated congressional districting as a non-justiciable 'political question.' Here, unlike in Colegrove, the legislature took a direct, affirmative act that, if the allegations were true, target only Black citizens for disenfranchisement rather than merely letting population shifts erode voting power over time.
- Applying the Fifteenth Amendment's bar on race-based denial of the vote, the Court reasoned that a law which achieves the 'inescapable human effect' of stripping voting rights from Black citizens alone cannot be shielded from judicial review simply because it is formally structured as a boundary redefinition.
- The Court concluded that when state power over its own subdivisions is used as a tool to circumvent a federally protected right, that use of power is not insulated from federal judicial review, so the complaint stated a valid constitutional claim that deserved a trial.
Doctrinal impact
Cases affected by this decision
Limits Hunter v. Pittsburgh (207 U.S. 161)
Clarifies that Hunter only bars contract- and tax-based challenges to boundary changes, not all constitutional challenges.
Distinguishes Colegrove v. Green (328 U.S. 549)
Says this case differs because it involves an affirmative act targeting a racial group, not mere population-shift vote dilution.
Reaffirms Graham v. Folsom (200 U.S. 248)
Relies on its rule that a state's power over its corporations is limited by other constitutional provisions.