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Gomillion v. Lightfoot - 364 U.S. 339, 81 S. Ct. 125 (1960)

Rule:

When a state exercises power wholly within the domain of state interest, it is insulated from federal judicial review. But such insulation is not carried over when state power is used as an instrument for circumventing a federally protected right.

Facts:

Plaintiffs C.G. Gomillion and several other African-American residents of the City of Tuskegee, Alabama ("City") filed a lawsuit in federal district court against defendants Phil M. Lightfoot, the Mayor of the City and several other local officials, seeking a declaratory judgment that Local Act No. 140, passed by the Legislature of Alabama in 1957, was unconstitutional. Plaintiffs also sought an injunction to restrain defendants from enforcing the statute against them and other similarly situated residents. Plaintiffs claimed that the statute, which redefined the boundaries of the City and removed all but a few African-American residents from the City's limits, constituted a discrimination against them in violation of the due process and equal protection clauses of the Fourteenth Amendment and denied them the right to vote, in defiance of the Fifteenth Amendment. On defendants' motion, the district court dismissed the action on the ground that the court had no control over any boundaries of municipal corporations fixed by a duly convened and elected legislative body. On appeal, the court of appeals affirmed. Plaintiffs were granted a writ of certiorari.

Issue:

Did the lower courts err in dismissing plaintiffs' complaint?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States reversed the lower courts' decisions and remanded the matter for further proceedings. The Court found that plaintiffs' allegations, if proven, would establish that Local Act No. 140 was not an ordinary geographic redistricting measure even within familiar abuses of gerrymandering. If the allegations upon a trial remained uncontradicted or unqualified, the conclusion would establish for all practical purposes that the legislation was solely concerned with segregating Caucasian and African-American voters by fencing the latter out of town so as to deprive them of their pre-existing municipal vote. Even the broad power of a State to fix the boundaries of its municipalities was limited by the Fifteenth Amendment, the Court ruled.

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