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City of Mobile v. Bolden

Supreme Court of the United States · 1980 · Constitutional Law

Constitutional LawEqual ProtectionVoting RightsFifteenth AmendmentFourteenth Amendmentat-large electionsvote dilutiondiscriminatory purpose

Facts

Since 1911, Mobile, Alabama, had been governed by a three-member City Commission elected at large, with each candidate running for one of three numbered posts and needing a majority of the total vote. The plaintiffs, suing on behalf of all Negro citizens of Mobile, alleged that this system unfairly diluted Negro voting strength. The District Court found that Negroes in Mobile registered and voted without hindrance and that there were no official obstacles to Negro candidacies, but it also found that no Negro had ever been elected to the City Commission, that voting was racially polarized, and that city officials had been less responsive to Negro interests than to white interests. Based on those findings, the lower courts held the system unconstitutional and ordered replacement with a mayor-council system using single-member districts.

Issue

Whether Mobile's at-large system for electing city commissioners violated § 2 of the Voting Rights Act, the Fifteenth Amendment, or the Equal Protection Clause of the Fourteenth Amendment by diluting the voting strength of Negro citizens. More specifically, the question was whether proof of discriminatory effect alone was sufficient, or whether purposeful racial discrimination had to be shown.

Rule

A facially neutral election system does not violate the Fifteenth Amendment or the Equal Protection Clause of the Fourteenth Amendment absent proof that it was motivated or maintained for a racially discriminatory purpose. Under this opinion, § 2 of the Voting Rights Act merely restates the Fifteenth Amendment and therefore does not provide a broader standard. Evidence such as lack of minority electoral success, racial bloc voting, unresponsiveness of officials, past discrimination, or majority-vote and numbered-post features may be relevant, but those factors alone do not establish unconstitutional vote dilution without proof of purposeful discrimination.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Riverton, Ohio elects its five city council members at large. Latino residents make up 30% of the city, register and vote freely, and may run for office without legal obstacle, but no Latino candidate has won because white and Latino voters usually support different candidates.

If Latino voters sue under the Equal Protection Clause alleging unconstitutional vote dilution, which is the strongest answer?

Explanation. The controlling rule is that a facially neutral electoral system does not violate the Fourteenth Amendment based on disproportionate impact alone. Lack of minority electoral success and racially polarized voting may be relevant evidence, but they are not sufficient by themselves. Plaintiffs must prove the plan was conceived or operated as a purposeful device to further racial discrimination. The Constitution does not guarantee proportional representation.