April 22, 1980court rulingvoting rightscivil rightsracial equityjudicial reviewvoting rightsracial justicecourts
Mobile v. Bolden: Supreme Court Guts VRA Section 2 with Intent Standard
The Supreme Court ruled 6-3 that the Voting Rights Act's Section 2 required plaintiffs to prove discriminatory intent, not merely discriminatory results, when challenging at-large election systems that diluted minority voting power. Justice Potter Stewart wrote the plurality opinion; Justice Thurgood Marshall dissented sharply, warning that the ruling would make it nearly impossible to challenge voting systems that excluded Black voters in practice. The case arose from Mobile, Alabama, where an at-large city commission structure had never elected a Black member despite a 35% Black population.