Mobile v. Bolden

446 U.S. 55, 100 S. Ct. 1490, 64 L. Ed. 2d 47, 1980 U.S. LEXIS 121



The Fifteenth Amendment imposes only one limitation on the powers of the state and that is forbidding them from discriminating against black citizens in matters concerning voting. The Fifteenth Amendment exempts individuals from discrimination in regards to race, color, or previous condition of servitude.


Bolden and other residents of Mobile, Alabama filed a class action on behalf of all black citizens of the city of Mobile. It was argued that electing only City Commissioners at-large unfairly diluted the strength of black citizens. The District Court and the U.S. Court of Appeals ruled in favor of the class action.


Did the at-large voting system violate the Fourteenth and Fifteenth Amendments?




The Court held that the Fifteenth Amendment was to protect an individual's right to vote, and that only purposefully discriminatory denials of the freedom to vote on the basis of race demanded constitutional remedies. The Court also found that multimember legislative districts were not unconstitutional on their face. They only violated the Fourteenth Amendment if they were "conceived or operated as [a] purposeful devic[e] to further racial. . .discrimination." The Court held that facially neutral actions were unconstitutional only if motivated by discriminatory purposes.

Click here to view the full text case and earn your Daily Research Points.