While multimember districts have been challenged for their winner-take-all aspects, their tendency to submerge minorities and to overrepresent the winning party they are not unconstitutional per se. Multimember districts violate the Fourteenth Amendment if conceived or operated as purposeful devices to further racial discrimination by minimizing, cancelling out or diluting the voting strength of racial elements in the voting population. Cases charging that multimember districts unconstitutionally dilute the voting strength of racial minorities are thus subject to the standard of proof generally applicable to equal protection clause cases. In order for the equal protection clause to be violated, the invidious quality of a law claimed to be racially discriminatory must ultimately be traced to a racially discriminatory purpose.
Appellant county had an at-large system for electing members of its governing Board of Commissioners. Appellee African-American citizens filed a class action, alleging that the system of elections violated their Fourteenth Amendment rights. The court held that the system of elections violated diluted appellees’ voting power and that the system was maintained for invidious purposes. The court then ordered the county to be divided into districts for purposes of electing county commissioners. The appellate court affirmed. The Supreme Court of the United States affirmed the lower court’s decision.
Did the at-large system of elections in appellant county violate the Fourteenth Amendment rights of appellee African-American citizens?
The lower court's determination was not clearly erroneous. It held that there was sufficient evidence to support a finding that appellee African-American citizens had been invidiously excluded from the political process by the appellant county's system of elections. The sheer geographic size of the county made it difficult for appellees to get to polling places or to campaign for office. The elections system submerged appellees’ will and thus, denied their access to the system. The requirement that candidates run for specific seats enhanced appellees' lack of access because it prevented a cohesive political group from concentrating on a single candidate.