Gomillion v. Lightfoot

In 1957, the majority of the residents of Tuskegee, Alabama, were Black. However, more White people were registered to vote in the city than Black people. Private efforts to register more Black voters began to narrow that gap. At that point, the state legislature passed a statute that changed the city’s boundaries to virtually eliminate all Black voters from the Tuskegee city limits. Prior to the statute, the city’s boundaries had formed a square. The statute changed the city’s shape to a 28-sided figure that some thought resembled a sea dragon. The statute’s effect was to remove all but four or five of Tuskegee’s 400 registered Black voters from the city’s limits. No White voters or residents were affected. Charles Gomillion (plaintiff) had been a Tuskegee resident before the boundary change. Gomillion and other former Tuskegee residents (collectively, Gomillion) (plaintiffs) sued Tuskegee mayor Phil Lightfoot and other officials (defendants), seeking a declaration that the statute was unconstitutional and an injunction prohibiting the city from enforcing it. Gomillion argued that the boundary-change statute violated (1) the Fourteenth Amendment, because it discriminated against him and the other displaced residents based on their race, and (2) the Fifteenth Amendment, because it deprived him and the other displaced residents of the right to vote in Tuskegee’s elections due to their race. Lightfoot moved to dismiss the case. The district court granted the motion, ruling that it had no authority over a state legislature’s municipal-boundary decisions. The United States Court of Appeals for the Fifth Circuit affirmed. The United States Supreme Court granted certiorari.