Multimember Electoral Systems and the Discriminatory Purpose Standard

Examines the United States Supreme Court’s decision in City of Mobile v. Bolden. In Bolden, black citizens of Mobile Alabama challenged an electoral system that allegedly violated their fourteenth and fifteenth amendment rights. The Court held that an at-large, multimember electoral system can only be invalidated by a finding of a discriminatory purpose, and not “on the basis of adverse effect alone.” The author believes that courts will have a difficult time discerning between intent and impact.