City of Mobile v. Bolden

Week 12 — Discriminatory Purpose

Facts

  • Mobile, Alabama, conducted at-large voting for its City Commission—meaning the entire city voted for each individual position.
  • Blacks made up 35% of Mobile's population, yet no Black person had ever won a seat on the Commission.
  • The election structure was challenged under the Equal Protection Clause.

Issue

Whether an at-large election structure with a markedly disparate racial outcome violates the EPC absent proof that the structure was adopted with discriminatory purpose.

Holding

No. Without proof of discriminatory purpose, the structure did not violate the EPC.

Reasoning

  • Claimants must prove that a challenged election structure was implemented with a discriminatory purpose—discriminatory impact alone does not suffice.
  • Individual acts of discrimination by an elected official may still be challenged, but they don't make the entire election process unlawful.

Notes

  • Applies the Washington v. Davis purpose requirement to elections.
  • See also Rogers v. Lodge (1982): at-large election systems can be unconstitutional, but only on adequate proof of discriminatory purpose; discriminatory result alone does not suffice.