City of Mobile v. Bolden

Summary

The Supreme Court considered whether Mobile, Alabama's at-large municipal election system violated § 2 of the Voting Rights Act, the Fourteenth Amendment, or the Fifteenth Amendment by diluting the voting strength of Black voters. The Court held that § 2, as then understood, added nothing to the Fifteenth Amendment claim and that a racially discriminatory purpose was required to establish a constitutional violation. It reversed the judgment upholding relief that would have replaced the commission system with a mayor-and-council system elected from single-member districts.

Holdings

1. Section 2, as then understood by the Court, did no more than restate the prohibition contained in the Fifteenth Amendment and therefore added nothing to appellees' claim; the Court assumed without deciding that a private right of action existed.
2. A facially racially neutral electoral system violates the Fifteenth Amendment only when racially discriminatory purpose is shown; because Mobile Negroes were permitted to register and vote without hindrance and the evidence did not establish purposeful denial or abridgment of the vote, the at-large system did not violate the Fifteenth Amendment.
3. An at-large or multimember electoral system is not unconstitutional per se. A Fourteenth Amendment violation requires proof that the system was conceived or operated as a purposeful device to minimize or cancel the voting strength of a racial or ethnic minority. The evidence in this case was insufficient to prove that purpose.
4. The Equal Protection Clause does not require proportional representation and does not protect a racial or political group from electoral defeat merely because it has not elected representatives in proportion to its population.

Questions Presented

1. Whether Mobile's at-large municipal election system violated § 2 of the Voting Rights Act of 1965.
2. Whether Mobile's at-large election system violated the Fifteenth Amendment by purposefully denying or abridging Negro citizens' right to vote on account of race.
3. Whether Mobile's at-large election system violated the Equal Protection Clause of the Fourteenth Amendment through purposeful racial vote dilution.
4. Whether the Constitution requires proportional representation or protects a racial or political group from electoral defeat merely because it has not elected candidates in proportion to its population.

Disposition

reversed_and_remanded