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Case Study: Gomillion V. Lightfoot

Posted on:May 2, 2022 at 12:00 PM

Gomillion V. Lightfoot


Gomillion v. Lightfoot was a case decided in 1960 regarding the gerrymandering of the city of Tuskegee, AL. When Charles A. Gomillion, a professor and dean of students at the Tuskegee Normal and Industrial Institute (present-day Tuskegee University) found out in 1957 that several white citizens were promoting a bill that would redefine the city boundaries to virtually ensure victories by whites in the upcoming 1960 election, he and other activists appealed to the City Council and lobbied the state legislature. Despite this, Local Act No. 140 went on to be passed and redrew the city boundary from a simple square to a convoluted, 28-sided polygon that would remove Tuskegee Institute and almost all black voters in the city while leaving in every white resident. In response, Gomillion and other petitioners went on to take legal action against city officials, starting at the District Court and appealing all the way to the Supreme Court.

Proceedings in the Court Below:

Legal proceedings were initially instituted in the U.S. District Court for the Middle District of Alabama by Gomillion and other petitioners versus Phil M. Lightfoot, the mayor of Tuskegee, and other officials from Macon County, AL. This proceeding was a civil action as the case was not criminal in nature, where the plaintiff is harmed in any way. The plaintiffs sought injunctive relief in the face of Act No. 140, as they believed that it openly violated the due process and equal protection clauses of the Fourteenth Amendment of the United States Constitution and was also in violation of the Fifteenth Amendment of the Constitution of the United States. The defendants, however, sought to have the court dismiss the complaint, reasoning that the complaint fails to state a claim against them upon which relief can be granted. The defendants go on to elaborate that fixing the boundaries of a city in Alabama is a matter for the Legislature of the State of Alabama insofar as they are acting in accordance with the State Constitution, and is thereby not subject to the jurisdiction, control or supervision of the Federal courts. District Judge Johnson delivered an opinion based on several court cases regarding the balance between municipal, state and federal power such as Laramie County Com’rs v. Albany County, Mount Pleasant v. Beckwith and Hunter v. City of Pittsburgh. In it, Johnson formed his opinion around the axiom, ‘If the State has the power to do an act, its intention or the reason by which it is influenced in doing it cannot be inquired into.’ Believing that as long as a state can legally carry out an action, its constitutionality cannot be inquired into or evaluated, Johnson granted the motion to dismiss the claim. This ruling was also upheld by the Court of Appeals for the Fifth Circuit in New Orleans. Subsequently, Gomillion et. al. would appeal to the Supreme Court.

Appellate resolution:

At the Supreme Court, the petitioners once again challenged the validity of Act No. 140, and called for an injunction to restrain the local officials of the City of Tuskegee from enforcing the act against them. The court, in an opinion written by Justice Frankfurter recognized the claims of the prosecution and acknowledged that if proven, they would establish that Act 140 is much more unorthodox than other abuses of gerrymandering and that its purpose was to deprive black residents of Tuskegee the right to vote. Frankfurter noted that the defendants and the district court judge used examples of court cases that generalize the state’s power over its municipalities to declare that the state has absolute power over its municipalities, independent of federal review. In fact, he points out that the state’s power to reorganize its municipalities is only given by the United States constitution, and that the defense has mischaracterized the Supreme Court’s reach in the example court cases. Frankfurter goes on to dismiss each of the example cases in this manner:

Particularly in dealing with claims under broad provisions of the Constitution, which derive content by an interpretive process of inclusion and exclusion, it is imperative that generalizations, based on and qualified by the concrete situations that gave rise to them, must not be applied out of context in disregard of variant controlling facts. Thus, a correct reading of the seemingly unconfined dicta of Hunter and kindred cases is not that the State has plenary power to manipulate in every conceivable way, for every conceivable purpose, the affairs of its municipal corporations, but rather that the State’s authority is unrestrained by the particular prohibitions of the Constitution considered in those cases.

On this line of reasoning, Frankfurter affirmed that the Supreme Court has never let the States do as they wish with their municipalities regardless of consequences. As a result, a state’s power does not transcend the Fifteenth Amendment to the Constitution, which forbids a state from passing any law which deprives a citizen of his vote because of their race. To conclude, Frankfurter recognizes:

When a State exercises power wholly within the domain of state interest, it is insulated from federal judicial review. But such insulation is not carried over when state power is used as an instrument for circumventing a federally protected right.

As a result, the court reversed the decision made by the District Court and the Court of Appeals. It should be noted that Justice Whittaker, although concurring in the judgment of the court, disagreed with part of its opinion. Arguing that the decision should be rested on the equal protection clause of the Fourteenth Amendment rather than the Fifteenth Amendment, Whittaker suggests that redistricting doesn’t take away a person’s right to vote if they are able to vote in the new district that they are placed in. However, the segregation of black voters into another district, Whittaker argues, is in violation of the equal protection clause.

Personal Opinion: Presented are two perspectives on the same case. On one hand is the perspective of the District Court decision, which argues that the state can undertake any act to the extent that it has power to do so and should not be questioned by the courts for doing so. On the other hand is the perspective of the Supreme Court decision, which argues that the state cannot pass acts that, while otherwise perfectly legal, accomplish an unlawful end. I believe that the case was judged fairly across the three levels of courts, in that there was no irregular procedural behavior observed by any of the courts. As for the matter of whose opinion was correct, I would side with the opinion of the Supreme Court. I believe that the District Court opinion fails to soundly evidence its argument that states have supreme eminence over their municipalities. Furthermore, I believe that the court, for the sake of their decision, ignored the content of Act 140 and presented it as merely fact, having no significance other than being an example of something a state can produce using its powers.

Judge Johnson, in his opinion, cites several cases that align with his interests:

The Supreme Court of the State of Alabama has the same authority insofar as the Constitution of the State of Alabama is concerned, that the Supreme Court of the United States has insofar as the Constitution of the United States is concerned. The authority of each court in interpreting and passing upon questions arising out of the respective Constitutions is supreme (Willys Motors, Inc., v. Northwest Kaiser-Willys, Inc., D.C., 142 F.Supp. 469).

Counties, cities, and towns are municipal corporations, created by the authority of the legislature; and they derive all their powers from the source of their creation, except where the constitution of the State otherwise provides (Laramie County Com’rs v. Albany County, 1875, 92 U.S. 307, 23 L.Ed. 552).

If the act done by the State is legal, is not in violation of the Constitution or laws of the United States, it is quite out of the power of any court to inquire what was the intention of those who enacted the law (Hunter v. City of Pittsburgh, 1907, 207 U.S. 161, 28 S.Ct. 40, 45, 52 L.Ed. 151).

In terms of legal precedent for his argument, Johnson had plenty to be able to make a ruling in the interest of the defendants. However, I feel as if Johnson should have done more to support his argument than simply state parts of certain cases that happened to fit well. Certainly, there are cases that disagree with the notion that states have power over their municipalities, and if he could have referenced a counterexample case and shown that the counterexample was not valid in this situation, his grounds for dismissal would have been much sounder.

As for the context of Act 140, the written opinion demonstrates that Johnson understands how discriminatory the act is. Johnson even writes:

As the boundaries are redefined by said Act No. 140, the municipality of Tuskegee resembles a ‘sea dragon.’ The effect of the Act is to remove from the municipality of Tuskegee all but four or five of the qualified Negro voters and none of the qualified white voters. Plaintiffs state that said Act is but another device in a continuing attempt to disenfranchise Negro citizens not only of their right to vote in municipal elections and participate in municipal affairs, but also of their right of free speech and press, on account of their race and color.

Yet, these findings had little relevance in the resulting analysis of state powers over its municipalities. This was because defining the scope of argument to exclude the content of the act passed by the state meant that the court did not have to argue against the nature of the act, which would have likely been harder to circumvent given the clear discrimination it puts in place.

As a result, I side with the Supreme Court opinion because it fixes the two things that were overlooked by the District Court ruling. Justice Frankfurter’s opinion considers counterexample cases, which are the cases that were cited in the District Court ruling, and decidedly argues as to why they do not support the District Court’s claim:

The Hunter case involved a claim by citizens of Allegheny, Pennsylvania, that the General Assembly of that State could not direct a consolidation of their city and Pittsburgh over the objection of a majority of the Allegheny voters. It was alleged that while Allegheny already had made numerous civic improvements, Pittsburgh was only then planning to undertake such improvements, and that the annexation would therefore greatly increase the tax burden on Allegheny residents. All that the case held was (1) that there is no implied contract between a city and its residents that their taxes will be spent solely for the benefit of that city, and (2) that a citizen of one municipality is not deprived of property without due process of law by being subjected to increased tax burdens as a result of the consolidation of his city with another.

Justice Frankfurter ultimately recognizes the legitimacy of the claims made by the prosecution and works arguments regarding the Fourteenth and Fifteenth Amendments into his opinion. In this sense he is truly considering this action a case of racial discrimination against the black citizens of Tuskegee rather than a discussion of the eminence of state powers. On a matter of principle, when people’s rights are in jeopardy due to discrimination, this is this opinion I agree with.