Landmark Supreme Court Case: Gomillion v. Lightfoot (1960)

by Kwaisi France · August 28, 2020

Gomillion v. Lightfoot (1960) is the 108th landmark Supreme Court case, third in the Elections module, featured in the KTB Prep American Government and Civics series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:

The Supreme Court

The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.

The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.

The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.

Court of Appeals

In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.

The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.

A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.

District Courts

The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.

Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.

There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.

Bankruptcy Courts

Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.

Gomillion v. Lightfoot (1960)

Gomillion Facts

In the city of Tuskegee, Alabama, after passage of the Civil Rights Act of 1957, activists had been slowly making progress in registering African-American voters, whose numbers on the rolls began to approach those of white registered voters. The city was the location of the Tuskegee Institute, a historically black college, and a large Veterans Administration hospital, both staffed entirely by African Americans.

In terms of total population, African Americans outnumbered whites in the city by a four-to-one margin, and whites were worried about being governed by the black majority. Local white residents lobbied the Alabama legislature to redefine the boundaries of the city. Without debate in 1957 and ignoring African-American protests, the legislature enacted Local Law 140, to form a 28-sided city boundary by which nearly all black voters would be excluded and no whites would be.

The act was written by state senator Samuel Martin Engelhardt Jr. who was executive secretary of the White Citizens’ Council of Alabama and an advocate of white supremacy. Charles G. Gomillion, a professor at Tuskegee, and other African Americans protested; community activists mounted a boycott against white-owned businesses in the city. Gomillion and others filed suit against the city mayor and other officials, claiming that the act was discriminatory in purpose under the Fourteenth Amendment’s due process and equal protection clause.

The U.S. District Court for the Middle District of Alabama, located in the capital of Montgomery, headed by Judge Frank M. Johnson, dismissed the case, ruling that the state had the right to draw boundaries of election districts and jurisdictions. This ruling was upheld by the Court of Appeals for the Fifth Circuit in New Orleans.

As head of Tuskegee, Booker T. Washington had promoted blacks advancing by education and self-improvement, with the expectation of being accepted by whites when they showed they were “deserving.” At the time of the U.S. Supreme Court hearing of this case, journalist Bernard Taper wrote:

Since the gerrymander was designed to defeat municipal suffrage rights of the highly “deserving” members of the Institute and the hospital staff, Session Law 140 has demonstrated, perhaps more than other symbols of Southern prejudice, the invalidity of Booker T. Washington’s advice.

The state’s redrawing of the city’s boundaries had the:

unintended effect of uniting Tuskegee Institute’s African-American intellectuals with the less educated blacks living outside the sphere of the school. Some members of the school’s faculty realized that possessing advanced degrees ultimately provided them no different status among the city’s white establishment.

Gomillion and his attorneys appealed the case to the US Supreme Court. The case was argued by Fred Gray, an experienced Alabama civil rights attorney, and Robert L. Carter, lead counsel for the National Association for the Advancement of Colored People (NAACP), with assistance from Arthur D. Shores, who provided additional legal counsel.

Gomillion Legal Questions and Answers

Q: Did the redrawing of Tuskegee’s electoral district boundaries violate the Fifteenth Amendment?

A: Yes. A state violates the Fifteenth Amendment when it constructs boundary lines between electoral districts for the purpose of denying equal representation to African Americans.

Gomillion Conclusion

Unanimous holding electoral district boundaries drawn only to disenfranchise blacks violate the Fifteenth Amendment. While states are insulated from judicial review when they exercise power “wholly within the “domain of state interest”, in this case, Alabama’s representatives were unable to identify “any countervailing municipal function” the act was designed to serve. The Court believed that the irregularly shaped district was drawn with only one purpose in mind: to deprive blacks of political power.

The case showed that all state powers were subject to limitations imposed by the U.S. Constitution; therefore, states were not insulated from federal judicial review when they jeopardized federally protected rights. The case was returned to the lower court; in 1961, under the direction of Judge Johnson, the gerrymandering was reversed and the original map of the city was reinstituted. In the 1980 case Mobile v. Bolden, the court limited its holding in Gomillion, ruling that racially discriminatory effect and intent would be necessary to prompt intervention by federal courts for violations of Section 2 of the Voting Rights Act.

Congress effectively negated Bolden in 1982 when it amended Section 2 of the Voting Rights Act, 42 U.S.C. § 1973. Congress’ amendments returned the law to the pre-Bolden interpretation, under which violations of Section 2 did not require a showing of racially discriminatory intent, but it was sufficient to show discriminatory effect. This legislation was important for the many subsequent cases challenging political and electoral systems that resulted in dilution of voting or other effects that deprived citizens of their ability to elect a candidate of their choice.

Next Elections Case: Baker v. Carr (1962)

Previous Elections Case: Colegrove v. Green (1946)

Next Case: Mapp v. Ohio (1961)

Previous Case: Jencks v. United States (1957)

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