Louisiana v. Callais · ¶139

Just seven years later, however, the Court did an about- face, now requiring a showing of discriminatory intent to succeed on a vote-dilution claim. In City of Mobile v. Bol den, the plaintiffs challenged an at-large election system for a three-member city commission. Under that system, Mobile's Black population, which made up 35% of the total, had never managed to elect a candidate of its choice. But the Court did not embark on the kind of analysis employed in White to determine whether the system diluted Black votes. Instead, the Court's controlling opinion held that Section 2 merely “restated the prohibitions” of the Fifteenth Amendment, which barred only intentional discrimination. 446 U. S., at 61 (plurality opinion); see id., at 62–65. And the plaintiffs had produced no evidence of discriminatory motive. They could, the Court noted (as though it were the end of the matter),…

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