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Gomillion v. Lightfoot | 364 U.S. 339 (1960)

In nineteen fifty-seven, the population of Tuskegee, Alabama, was majority African American, but Whites outnumbered Blacks as registered voters. Concerned about an increasingly successful drive to register more Black voters, the state legislature redrew the city’s boundaries to virtually eliminate all Black voters from within Tuskegee city limits. In Gomillion versus Lightfoot, the plaintiff challenged the constitutionality of this maneuver.

The original boundaries of the city of Tuskegee formed a square. The legislature enacted Local Act Number One Forty, changing the shape of the city’s boundaries to a twenty-eight-sided figure that some likened to the shape of a sea dragon. The act’s effect was to remove from the city all but four or five of Tuskegee’s four hundred registered Black voters. No White voters or residents were affected.

Charles Gomillion, who’d been a Tuskegee resident before the boundary change, sued Phil Lightfoot, Tuskegee’s mayor, seeking a declaratory judgment that the act was unconstitutional and an injunction prohibiting the city from enforcing it. Gomillion argued that the act violated the Fourteenth Amendment’s Due Process and Equal Protection Clauses, and the Fifteenth Amendment’s prohibition against denying citizens the right to vote. Gomillion asserted that the act deprived him and others similarly situated of the benefits of residence in Tuskegee, including the right to vote in municipal elections, because of race.

Lightfoot moved to dismiss the case for lack of jurisdiction and failure to state a claim on which relief could be granted. The district court granted Lightfoot’s motion, ruling that it had no authority over a state legislature’s municipal-boundary decisions. The Fifth Circuit affirmed. The United States Supreme Court granted cert.

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