City of Mobile v. Bolden case brief

City of Mobile v. Bolden case brief summary
446 U.S. 55 (1980)

CASE SYNOPSIS

Appellee minority citizens sued appellants, city and its incumbent commissioners, alleging that the election of the city's commissioners at large violated their constitutional rights as well as § 2 of the Voting Rights Act of 1965, 42 U.S.C.S. § 1973. A district court's judgment in the citizens group's favor was affirmed by the United States Court of Appeals for the Fifth Circuit, and the city and commissioners appealed.

CASE FACTS
Since 1911 Mobile was governed by a city commission consisting of three members elected at large. Minority citizens sued the city and its incumbent commissioners alleging that the election of the commissioners at large violated their constitutional rights and § 2 of the Voting Rights Act of 1965, 42 U.S.C.S. § 1973. The district court entered a judgment in favor of the minority citizens and ordered that the city commission be disestablished and replaced by a mayor and city council elected from single-member districts. The lower appellate court affirmed the district court's judgment.

DISCUSSION

• On appeal, the Court reversed the appellate court's decision. 
• The Court held that, having found that Negroes in Mobile register and vote without hindrance, the lower courts erred in believing the Fifteenth Amendment was abridged. 
• The Court held further that the evidence fell short of showing that the city and commissioners conceived or operated a purposeful device to further racial discrimination, a showing essential to prove an equal protection violation. 
• The Court held that political groups do not have a right to claim representation independent from the right of individuals to vote on an equal basis.

CONCLUSION
The judgment was reversed and the case remanded for further proceedings.

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