Notes
Slide Show
Outline
1
GOMILLION v. LIGHTFOOT, 364 U.S. 339 (1960)
  • Negro citizens sued in a Federal District Court in Alabama for a declaratory judgment that an Act of the State Legislature changing the boundaries of the City of Tuskegee is unconstitutional and for an injunction against its enforcement.
2
Fourteenth and Fifteenth Amendments
  • The Fourteenth Amendments prohibits state action denying any person the equal protection of the laws.


  • The Fifteenth Amendment Section. 1. "The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of race, color, or previous condition of servitude."
3
Challenge to City Boundary
  • They alleged that the Act alters the shape of Tuskegee from a square to an irregular 28-sided figure;


  • that it would eliminate from the City all but four or five of its 400 Negro voters without eliminating any white voter;
4
Unconstitutional Racial Classification
  • [Plaintiffs further alleged that the law’s effect] was to deprive Negroes of their right to vote in Tuskegee elections on account of their race.




5
State Alleged Case was a Political Question
  • The respondents moved for dismissal of the action for failure to state a claim upon which relief could be granted and for lack of jurisdiction of the District Court.


  • [Essentially the state claimed this was a political question outside of the jurisdiction of the federal courts]
6
District Court Dismissal of Complaint
  • The District Court dismissed the complaint, on the ground that it had no authority to declare the Act invalid or to change any boundaries of municipal corporations fixed by the State Legislature.
7
Circuit Court Affirmed Dismissal of Complaint
  • On appeal, the Court of Appeals for the Fifth Circuit, affirmed the judgment, one judge dissenting. 270 F.2d 594.
8
Justice Frankfurter for the Supreme Court

  • We brought the case here since serious questions were raised concerning the power of a State over its municipalities in relation to the Fourteenth and Fifteenth Amendments.


9
Do Allegations Raise Constitutional Issue?


  • The sole question is whether the allegations entitle [the African-American Plaintiffs] to make good on their claim that they are being denied rights under the United States Constitution.
10
Plaintiffs Allegation
  • Prior to Act [of the Alabama legislature] the City of Tuskegee was square in shape;


  • the Act transformed it into a strangely irregular twenty-eight-sided figure as indicated in the diagram appended to this opinion.


11
Effect of Boundary Change
  • The essential inevitable effect of this redefinition of Tuskegee's boundaries is to remove from the city all save only four or five of its 400 Negro voters while not removing a single white voter or resident.


12
Exclusive State Powers
  • When a State exercises power wholly within the domain of state interest, it is insulated from federal judicial review.


  • [In Colegrove v. Green (1946) we held that state apportionment of congressional electoral districts was a political question beyond federal court jurisdiction]
13
Federal Courts have Jurisdiction to Hear Claims of Violation of Constitutional Rights
  • [State] insulation [from federal judicial power] is not carried over when state power is used as an instrument for circumventing a federally protected right [as here].


14
Ruling
  • The petitioners are entitled to prove their allegations at trial.


  • For these reasons, the principal conclusions of the District Court and the Court of Appeals are clearly erroneous and the decision below must be
  •    Reversed.