GOMILLION V. LIGHTFOOT

Felix Frankfurter remains something of an enigma. An activist in early life, after his appointment to the Supreme Court, he came to stand for a restraint that seemed at odds with his past. The opinions he wrote while he was on the Court also often seem to contradict each other. In the case of Gomillion v. Lightfoot, Charles G. Gomillion, a Black citizen of Tuskegee, Alabama, sued Phil M. Lightfoot, Tuskegee's mayor, along with other city and county officials over a gerrymandering scheme that changed city boundaries in a way that deprived almost all Tuskegee's registered African American voters of their franchise in municipal elections while not taking the right to vote away from a single white citizen. Here, in one of his last opinions, Frankfurter was willing to sidestep his own carefully formulated prohibition against adjudicating apportionment disputes so that he could strike down a state law that discriminated against Black voters. In his opinion in Gomillion v. Lightfoot, he argued that the law was a violation of the Fifteenth Amendment, which prohibits states from denying anyone the right to vote on account of race, color, or previous condition of servitude.