Facts
- Alabama enacted Local Act No. 140 (1957) redefining the municipal boundaries of Tuskegee.
- The Act changed Tuskegee’s limits from a simple square into an irregular 28-sided shape.
- Black residents alleged the new lines would remove all but four or five of roughly 400 Black voters from the city while removing no white voters.
- The practical effect alleged was to exclude nearly all Black residents from voting in Tuskegee municipal elections, despite increasing Black voter registration.
- Petitioners sought declaratory and injunctive relief against local officials charged with administering the new boundaries and elections.
Issues
- Whether federal courts may review a state statute redefining municipal boundaries when the change is alleged to disenfranchise Black citizens in municipal elections because of race.
- Whether a boundary change whose alleged inevitable effect is to deprive Black citizens of the right to vote in municipal elections on account of race violates the Fifteenth Amendment.
Decision
- The Supreme Court unanimously reversed the dismissal and remanded for further proceedings.
- The Court held the complaint stated a claim under the Fifteenth Amendment.
- The Court rejected the view that a state’s broad authority over municipal boundaries makes such boundary changes immune from constitutional review.
- The Court concluded that allegations of boundary manipulation designed to eliminate Black voting power in municipal elections are justiciable and, if proven, unconstitutional.
Legal Principles
- A state’s power to define or alter municipal boundaries is limited by the Fifteenth Amendment’s prohibition on denying or abridging the right to vote on account of race.
- A law may violate the Fifteenth Amendment even if race-neutral in form when its intended and inevitable operation is racial disenfranchisement.
- Racial disenfranchisement claims are not barred as nonjusticiable simply because the state used a “political” device such as municipal boundary revision.
- At the pleading stage, extreme boundary configurations combined with stark racial effects can support an inference sufficient to require adjudication on the merits.
Conclusion
The Court held that allegations Tuskegee’s boundaries were redrawn to exclude Black citizens from municipal elections stated a Fifteenth Amendment claim, and that state control over municipal lines cannot be used to deny voting rights on the basis of race.