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City of Mobile v. Bolden

Law Dictionary
CASE BRIEFS

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Constitutional Law Keyed to Stone

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

Brief Fact Summary. Each of Mobile, Alabama’s City Commissioners was elected under an at-large voting scheme. No black had ever been elected to the Commission. The Appellees, Bolden and others (Appellees), challenged the constitutionality of the at-large system.

Synopsis of Rule of Law. At-large electoral schemes are invalid only if their purpose is invidiously to minimize or cancel out the voting potential of racial or ethnic minorities.


Facts. Mobile Alabama was governed by a City Commission consisting of three commissioners. Each of the three commissioners was elected by the residents of the city at-large. Although Mobile has a substantial black population, no black has ever been elected to the Commission. The Appellees challenged the at-large system on Equal Protection grounds.

Issue. Did the at-large electoral system of mobile unconstitutionally dilute the voting strength of blacks?

Held. No.
Justice Potter Stewart (J. Stewart) stated that the right to equal participation in the electoral process is aimed not for the protection of any political group.
Moreover, J. Stewart said the evidence here fell short of that required to show that the Appellant, the City of Mobile (Appellant), operated a voting system with the intent to racially discriminate.

Dissent.
Justice William Brennan (J. Brennan) stated that proof of discriminatory impact should be sufficient in these types of cases to make out an Equal Protection case. Appellees have met their burden in this regard.
Justice Byron White (J. White) said the findings of the District Court amply support an inference of purposeful discrimination.
Justice Thurgood Marshall (J. Marshall) stated that the burden of proof should have shifted to the Appellant to show they refused to modify their districting scheme, despite, not because of, the severe discriminatory effects. This case is analytically the same as the voter dilution cases.
Concurrence.
Justice Harry Blackmun (J. Blackmun) concurred in the Supreme Court of the United States’ (Supreme Court) judgment of reversal because he believed the relief given by the District Court, changing the form of the City’s government to a mayor-council system, was inappropriate.
Justice John Paul Stevens (J. Stevens) said this case does not belong in the category of cases calling for strict scrutiny. (J. Stevens) also said this case draws into question a political structure that treats all individuals as equals, but adversely affects the political strength of a racially identifiable group.

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Discussion. The key to this case is that there is a difference, in the eyes of the Supreme Court, between diluting the voting strength of minorities as individuals and diluting the voting strength of minorities as a group. This case involves the latter.

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