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Mobile v. Bolden
City of Mobile v. Bolden is a case that was decided in 1980 by the United States Supreme Court. The court ruled that the at-large election system for city commissioners in the city of Mobile, Alabama, did not violate the Fourteenth and Fifteenth Amendments of the United States Constitution. The decision also established that a claim of minority vote dilution cannot be made without proof of racially discriminatory intent. Two years later, Congress amended the Voting Rights Act of 1965 to "provide that a plaintiff could establish a violation [of the law] without having to prove discriminatory intent."[1][2]
Background
In 1911, the city of Mobile, Alabama, adopted a commissioner-based form of government. The three elected commissioners each ran separate executive departments of the city government. The board was elected at large rather than by district, which effectively gave the city's white majority control over the election. In the late 1970s, a class-action suit against the city and the board of commissioners was filed on behalf of the black residents of Mobile, alleging that the at-large system violated their rights under the Fourteenth and Fifteenth Amendments of the United States Constitution, as well as Section 2 of the Voting Rights Act. A federal district court ruled in favor of the plaintiffs. The city appealed, and the appeals court affirmed the district court's ruling. The city appealed to the United States Supreme Court, which agreed to hear the case in 1979.[1][3]
Decision
In 1980, the Supreme Court decided 6-3 in favor of the city of Mobile. The majority opinion was written by Justice Potter Stewart and joined by Chief Justice Warren Burger and Justices Harry Blackmun, Lewis Powell, William Rehnquist and John Paul Stevens. The court ruled that the Fifteenth Amendment did not entail "the right to have Negro candidates elected." The court further decided that only intentionally discriminatory vote dilution warranted a constitutional remedy and that plaintiffs in such cases must prove that the racial discrimination was intentional. Justice Stewart wrote the following in the court's majority opinion:[4]
| “ | ...action by a State that is racially neutral on its face violates the Fifteenth Amendment only if motivated by a discriminatory purpose. In Guinn v. United States, 238 U.S. 347, this Court struck down a "grandfather" clause in a state constitution exempting from the requirement that voters be literate any person or the descendants of any person who had been entitled to vote before January 1, 1866. It was asserted by way of defense that the provision was immune from successful challenge, since a law could not be found unconstitutional either "by attributing to the legislative authority an occult motive" or because of conclusions concerning its operation in practical execution and resulting discrimination arising . . . from inequalities naturally inhering in those who must come within the standard in order to enjoy the right to vote. Despite this argument, the Court did not hesitate to hold the grandfather clause unconstitutional, because it was not "possible to discover any basis in reason for the standard thus fixed other than the purpose" to circumvent the Fifteenth Amendment.[5] | ” |
| —Justice Potter Stewart | ||
Justices William Brennan, Byron White, and Thurgood Marshall dissented. Marshall wrote the following in his dissent:[4]
| “ | Indeed, a plurality of the Court concludes that, in the absence of proof of intentional discrimination by the State, the right to vote provides the politically powerless with nothing more than the right to cast meaningless ballots. The District Court in both of these cases found that the challenged multimember districting schemes unconstitutionally diluted the Negro vote. These factual findings were upheld by the Court of Appeals, and the plurality does not question them. Instead, the plurality concludes that districting schemes do not violate the Equal Protection Clause unless it is proved that they were enacted or maintained for the purpose of minimizing or canceling out the voting potential of a racial minority. The plurality would require plaintiffs in vote-dilution cases to meet the stringent burden of establishing discriminatory intent within the meaning of Washington v. Davis, 426 U.S. 229 (1976); Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252 (1977); and Personnel Administrator of Mass. v. Feeney, 442 U.S. 256 (1979).[5] | ” |
| —Justice Thurgood Marshall | ||
Later developments
In 1982, Congress concluded that Section 2 of the 1965 Voting Rights Act should be amended to provide that a plaintiff could establish a violation of the section if the evidence established that, in the context of the "totality of the circumstance of the local electoral process," the standard, practice, or procedure being challenged had the result of denying a racial or language minority an equal opportunity to participate in the political process.[2]
See also
- Voting Rights Act
- Amendment XIV, United States Constitution
- Amendment XV, United States Constitution
External links
Footnotes
- ↑ 1.0 1.1 Oyez.org, "City of Mobile v. Bolden," accessed October 6, 2015
- ↑ 2.0 2.1 United States Department of Justice, "History of Federal Voting Rights Laws," accessed October 6, 2015
- ↑ protectcivilrights.org, "Voting Rights in Alabama, 1982-2006," July 2006
- ↑ 4.0 4.1 Cornell University Law School, "City of Mobile v. Bolden," accessed October 6, 2015
- ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
