City of Mobile v. Bolden Case Brief

Why is the case important?

The Petitioner, the City of Mobile (Petitioner), has a 3-person council. The councilmen run in an open election, where the majority vote getters are awarded seats on the council. Although the Petitioner City has a large black population, it has never had a black councilman.

Facts of the case

Wiley L. Bolden and other residents of Mobile, Alabama brought a class action on behalf of all black citizens in Mobile. They argued that the practice of electing the City Commissioners at-large unfairly diluted the voting strength of black citizens. A district court and the U.S. Court of Appeals for the Fifth Circuit ruled in favor of Bolden.

Question

Does the at-large system of municipal voting violate the rights of the black voters of the Petitioner City?

Answer

No. Reverse Court of Appeals.
There is no indication that this type of government was developed to purposely prevent a black person from being mayor. State action that is racially neutral on its fact violates the Fifteenth Amendment only if it is motivated by a discriminatory purpose. Multi-member legislative districts will only be found unconstitutional when their purpose is to minimize the voting power of racial minorities. It is not enough only to show that minority council members were not elected in proportion to their percentage of the total population.

Conclusion

The Supreme Court of the United States found that black citizens in Mobile register and vote without hindrance. Reversing, the Court held that the lower courts erred in believing that 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.

  • Case Brief: 1980
  • Appellant: City of Mobile
  • Appellee: Bolden
  • Decided by: Burger Court

Citation: 446 US 55 (1980)
ReArgued: Oct 29, 1979
Decided: Apr 22, 1980
Argued: Mar 19, 1979