Mobile v. Bolden
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.
Did the at-large system violate the Fourteenth and Fifteenth Amendments?
No. The Court held that the Fifteenth Amendment did not entail "the right to have Negro candidates elected," and that only purposefully discriminatory denials of the freedom to vote on the basis of race demanded constitutional remedies. The Court also found that multimember legislative districts were not unconstitutional per se; such legislative apportionments only violated the Fourteenth Amendment if they were "conceived or operated as [a] purposeful devic[e] to further racial. . .discrimination." In short, the Court held that facially neutral actions were unconstitutional only if motivated by discriminatory purposes.
