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.