Case Summary

In the late 1970s, a group of African-American voters filed a federal lawsuit against the City of Mobile, Alabama, and its City Commissioners challenging the City’s at-large method of electing its Commissioners as diluting African-American voting strength in violation of the U.S. Constitution’s 14th and 15th Amendments and § 2 of the federal Voting Rights Act (“VRA”).

  • The federal district court struck down the at-large election method as unconstitutional and ordered the city to implement a new system with a Mayor and City Council elected from single-member districts. Defendants appealed to the U.S. Court of Appeals for the Fifth Circuit.
  • The Fifth Circuit affirmed the district court’s decision and remedy. Defendants appealed to the U.S. Supreme Court.
  • On April 22, 1980, SCOTUS reversed and upheld the at-large election method as lawful. The Court explained that the 15th Amendment only prohibits purposeful discrimination and abridgement of the right to vote on account of race or color and African-Americans in Mobile were able to register and vote without hinderance. The Court also found that disproportionate effects alone were insufficient to establish a racial discrimination claim under the 14th Amendment; purposeful discrimination is required. Finally, the Court held that § 2 of the VRA was intended to have the same effect as the 15th Amendment itself and therefore only prohibited purposeful racial discrimination.

Significance: § 2 of the Voting Rights Act, based on its language and legislative history, was "intended to have an effect no different from that of the 15th Amendment itself" and therefore only prohibited purposeful discrimination as the 15th Amendment does.*

[*Note: Dissatisfied with the Court's interpretation of § 2, Congress passed the 1982 Amendments to the Voting Rights Act, explicitly overturning this case's ruling by expanding § 2's prohibition to bar any voting practice that purposefully discriminates or that has a discriminatory effect, regardless of whether it was enacted with a discriminatory purpose or intent. See Thornburg v. Gingles]

Case Library

U.S. Supreme Court - 446 U.S. 55 (1980)