Facts of the Case

An act of the Alabama legislature re-drew the electoral district boundaries of Tuskegee, replacing what had been a region with a square shape with a twenty-eight sided figure. The effect of the new district was to exclude essentially all blacks from the city limits of Tuskegee and place them in a district where no whites lived.

Question

Did the redrawing of Tuskegee's electoral district boundaries violate the Fifteenth Amendment of the Constitution which prevents the United States or any individual state from denying a citizen the right to vote on account of race, color, or previous condition of servitude?

Conclusion

The unanimous Court held that Act 140 of the Alabama legislature violated the Fifteenth Amendment. Justice Frankfurter admitted that states are insulated from judicial review when they exercise power "wholly within the domain of state interest." However, in this case, Alabama's representatives were unable to identify "any countervailing municipal function" which the act was designed to serve. It was clear to the Court that the irregularly shaped district was drawn with only one purpose in mind, namely, to deprive blacks of political power.