Since 1911, the city of Mobile, Alabama, was governed by a three member commission who were all elected at large. In the late 1970s, a group of African American voters in the city filed a federal lawsuit against the City and its Commissioners, alleging that the at large electoral system had the effect of diluting African American voting strength in violation of the 14th Amendment, 15th Amendment, and Section 2 of the Voting Rights Act of 1965. The U.S. District Court for the Southern District of Alabama held that the at-large system did violate the plaintiffs constitutional rights and ordered that the City Commission be replaced with a government run by a Mayor and City Council elected from single-member districts. The City and Commissioners appealed that ruling to the U.S. Court of Appeals for the Fifth Circuit, who affirmed the district court's ruling and remedy.
In 1980, the U.S. Supreme Court reversed the lower courts' rulings and held for the defendant-appellants, finding that the at-large electoral system did not violate the 14th Amendment, 15th Amendment, or Section 2 of the Voting Rights Act. The Court stated that the 15th Amendment does not guarantee the right to have African American candidates elected, but rather only prohibits purposeful discrimination and abridgement of the right to vote on account of race or color, and African Americans in Mobile are able to register and vote without any hindrance. For racial discrimination claims under the 14th Amendment, the Court held that disproportionate effects alone are insufficient to establish a violation; instead, purposeful discrimination is required.
Significance: Section 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 Section 2, Congress passed the 1982 Amendments to the Voting Rights Act, explicitly overturning this case's ruling by expanding Section 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]
U.S. Supreme Court - 446 U.S. 55 (1980)
- Opinion - 4/22/80