Gomillion v. Lightfoot
Gomillion v. Lightfoot is a landmark Supreme Court case centered on the issue of gerrymandering, specifically related to the redrawing of city limits in Tuskegee, Alabama. In this case, the city boundaries were altered in such a way that effectively disenfranchised nearly all African American voters while retaining the voting power of white residents. The Supreme Court, led by Justice Felix Frankfurter, unanimously ruled against this discriminatory practice, asserting that such manipulations of electoral boundaries violated the voting rights of African Americans under the Fifteenth Amendment. This decision marked a significant departure from Frankfurter's prior position in Colegrove v. Green, where he had deemed legislative redistricting a political issue for state legislatures.
The ruling in Gomillion v. Lightfoot underscored the Court's role in protecting voting rights and set a precedent for future cases challenging gerrymandering. Justices Douglas and Whittaker, while concurring with Frankfurter’s opinion, suggested that the Fourteenth Amendment could also be invoked against such practices. The case highlights the ongoing struggles surrounding electoral equity and the legal mechanisms employed to address systemic discrimination in voting. Overall, Gomillion v. Lightfoot serves as a critical reference point in discussions about race, representation, and the integrity of electoral processes in the United States.
Gomillion v. Lightfoot
Date: November 14, 1960
Citation: 364 U.S. 339
Issue: Gerrymandering
Significance: The Supreme Court struck down racial gerrymandering in Tuskegee, Alabama, opening the door for a reconsideration of the justiciability of redistricting cases.
Justice Felix Frankfurter wrote the unanimous opinion of the Court overturning the arbitrary redrawing of the city limit lines in Tuskegee, Alabama, in such a way as to eliminate all but four or five African American voters while eliminating no white voters. In doing so, Frankfurter had to get around his own opinion in Colegrove v. Green (1946) in which he had concluded that legislative redistricting was a political question best left to the legislature. He did not drop his opposition to general judicial review of legislative districts, using the Fifteenth Amendment’s voting rights principle rather than the Fourteenth Amendment in his reasoning in Gomillion. He defended his Colegrove opinion in his dissent in Baker v. Carr (1962). Justices William O. Douglas and Charles E. Whittaker concurred but said they would have struck down the gerrymandering on Fourteenth Amendment grounds, foreshadowing the overturning of Colegrove by Baker.
