Gomillion v. Lightfoot [1960]
364 U.S. 339 · Supreme Court of the United States · United States
Issue
Whether a state law that alters municipal boundaries in a way that removes virtually all Black voters from the city violates the Fifteenth Amendment's prohibition on racial discrimination in voting.
Held
Yes. Although a state generally has plenary power over municipal boundaries, that power cannot be used to deprive citizens of the right to vote on account of race.
Exam use
Summary
Whether a state law that alters municipal boundaries in a way that removes virtually all Black voters from the city violates the Fifteenth Amendment's prohibition on racial discrimination in voting.
Facts
Issue
Whether a state law that alters municipal boundaries in a way that removes virtually all Black voters from the city violates the Fifteenth Amendment's prohibition on racial discrimination in voting.
Held
Yes. Although a state generally has plenary power over municipal boundaries, that power cannot be used to deprive citizens of the right to vote on account of race.
Ratio Decidendi
The Fifteenth Amendment forbids the state from denying or abridging the right to vote on account of race. While the state has broad authority to define municipal boundaries, that authority is subject to constitutional limitations. When the boundary change is so clearly drawn along racial lines that its purpose and effect are to exclude Black citizens from voting in municipal elections, it violates the Fifteenth Amendment. The Court distinguished Hunter v. City of Pittsburgh, noting that Hunter did not involve a racial discrimination claim under the Fifteenth Amendment.
Reasoning
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Reference to Gomillion v. Lightfoot (364 U.S. 339) strengthens a Local Government Law answer because the case reflects the principle that The Fifteenth Amendment forbids the state from denying or abridging the right to vote on account of race. While the state has broad authority to define municipal boundaries, that authority is subject to constitutional limitations. When the boundary change is so clearly drawn along racial lines that its purpose and effect are to exclude Black citizens from voting in municipal elections, it violates the Fifteenth Amendment. The Court distinguished Hunter v. City of Pittsburgh, noting that Hunter did not involve a racial discrimination claim under the Fifteenth Amendment. Applied to a problem question, the case should be used after identifying the issue as Whether a state law that alters municipal boundaries in a way that removes virtually all Black voters from the city violates the Fifteenth Amendment's prohibition on racial discrimination in voting. The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.
Underlying Concepts
- fifteenth amendment
- racial discrimination
- municipal boundaries
- voting rights
- gerrymandering
- state power limitation
Significance
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