Complaint with cover letter to Charles Williams from James Blacksher

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CRAWFORD, BLACKSHER & KENNEDY 

ATTORNEYS AT LAW 

  

1407 DAVIS AVENUE 

MOBILE, ALABAMA 36603 

VERNON Z. CRAWFORD TELEPHONE 432-1691 

JAMES U. BLACKSHER AREA CODE (205) 

CAIN J. KENNEDY 

MICHAEL A. FIGURES 

W. CLINTON BROWN, JR. 

December 9, 1975 

Charles Williams, Esquire 
Suite 2030 
10 Columbus Circle 
New York, N. Y. 10019 

Re: Bolden, et al. v. City of Mobile, et al. 
Brown, et al. v. Moore, et al. 
  

Dear Charles: 

Enclosed are selected pleadings from the Mobile City and County 
Commission redistricting lawsuits. 

I have discussed your interest in these cases with Mr. LeFlore, 
and, as I fully expected, he would be delighted for Legal Defense 
Fund to participate in every way you are able. Go ahead and 
draft a notice of appearance and send it to me for filing. 

Please accept my personal thanks for helping out. 

Best regards. 

Sincerely, 

CRAWFORD & BLACKSHER 

gai 

q. U. Blacksher 
\: 

JUB: bm 

Enclosures 

cc: Edward Still, Esquire 
John L. LeFlore 

 



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IN THE UNITED STATES DISTICT COURT FOR THE 
SOUTHERN DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

  

  

WILLY L. BOLDEN. REV. R.L. HOPE, 
CHARLES JOHNSON, JANET O. LEFLORE, 
JOHN L. LEFLORE, CHARLES MAXWELL, 
OSSIE B. PURIFOY, RAYMOND SCOTT, 
SHERMAN SMITH, OLLIE LEE TAYLOR, 
RODNEY O. TURNER, REV. ED WILLIAMS, 
SYLVESTER WILLIAMS AND MRS. F. C. 
WILSON , 

Plaintiffs; 

CIVIL ACTION NG.75=2%7- 4 VS.   

CITY OF MOBILE, ALABAMA; GARY A. 
GREENOUGH,. ROBERT B.. DOYLE, JR., 
AND LAMBERT C. MIMS, individually 
and in their official capacities 
as Mobile City Commissioners, 

Defendants. 

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COMPLAINT   

I. 

Jurisdiction 
  

Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 

§§ 1330 and 1343. The amount in controversy exceeds $10,000.00 

exclusive of interest and costs. This is a suit in equity arising 

out of the Constitution of the United States, the First, Thirteenth, 

Fourteenth, and Fifteenth Amendments, and 42 U.S.C. Sec. 1973, 1983 

and 1833. (3). 

II. 

Class Action 
  

Plaintiffs bring this action on their own behalf and on behalf 

of all other persons similarly situated pursuant to Rule 23 (a) and 

23 (b) (2), Federal Rules of Civil Procedure. The class which plain- 

tiffs dorrosent 15 composed of black citizens of the City of Mobile, 

Alabama. All such persons have been, are being, and will be adverse- 

ly affected by the defendants' practices complained of herein. There 

are common questions of law and fact affecting the rights of the 

members of this class, who are, and continue to be, deprived of the 

equal protection of the laws because of the election system detailed 

below. . These persons are so numerous that “joinder of all members 

 



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1s impracticable. There are questions of law and fact common to 

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plaintiffs and the class they represent. The interests of said 

class are fairly and adequately represented by the named plain- 

tiffs. The defendants have acted or refused to act on grounds 

generally applicable to the class, thereby making appropriate 

final injunctive relief and corresponding declaratory relief 

with respect to the class as a whole. 

111. 

Parties 

A. Plaintiffs Wiley L. Bolden, Rev. R. L. Hope, Charles 

Johnson, Janet 0. LeFlore, John L. LeFlore, Charles Maxwell, 

Ossie B. Purifoy, Raymond Scott, Sherman Smith, Ollie Lee Taylor, 

Rodney 0. Turner, Rev. Ed Williams, Sylvester Williams and Mrs. 

F. C. Wilson are black citizens of the City of Mobile, Alabama, 

over the age of 21 years. 

B. Defendants, Gary A. Greenough ., Robert B. Doyle, Jr., 

and Lambert C. Mims are each over the age of 21 years and are 

bona fide citizens of Mobile, Alabama. The defendants are the 

duly elected City Commissioners of Mobile. 

lv. 

Nature of Claim 
  

A. The Mobile City Commission is the governing body of 

the City of Mobile, holding the legislative power granted to 

cities. In addition, its members perform certain administrative 

ad executive functions. 

B. The Mobile City Commission is organized under Act 

163, Reg. Sess. 1911, as amended. 

C. The three (3) commissioners on the City Commission are 
elected at large to numbered places. 

D. The City of Mobile has a total population of 190,026, 
of whom 35.4% or 67,356 are black. Certain areas of Mobile are 

"almost totally devoid of blacks, whilesothers are Virtudlly all 
black. Segregated housing patterns have resulted in concentra- 
tions of black voting power. 

 



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E. The present system of electing city commissioners dis- 

  

criminates against black residents of Mobile in that their con- 

centrated voting strength is diluted and canceled out by the white 

majority in the city as a whole. 

¥. 

Plaintiffs and the class theyrepresent have no plain, 

adequate or complete remedy at law to redress the wrongs alleged 

herein, and this suit for a permanent injunction is their only 

means of securing adequate relief. Plaintiffs and the class they 

represent are now suffering and will continue to suffer irreparable 
described 

injury from the unconstitutional election system /herein. 

WHEREFORE, plaintiffs respectfully pray this Court to advance 

this case on the docket, order a speedy hearing at the earliest 
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practicable date, cause Shiels be in every way expedited and upon 

such hearing to: 

1. Grant plaintiffs and the class they represent a 

declaratory judgment that the election system com- 

plained of herein violates the First, Thirteenth, 

Fourteenth, and Fifteenth Amendments to the Consti- 

tution of the United States and 42 U.8.C. Secs. 1973, 

1933 and 19835(3). 

oH Grant plaintiffs and the class they represent an 

order enjoining the defendants, their agents, succes- 

sors, attorneys and those acting in concert with them 

and at their direction from holding, supervising, or 

certifying the results of any election for the Mobile 

City Commission under the present at-large election 

system and from failing to adopt a plan of city govern- 

ment using single-member districts. 

3 ward plaintiffs and the class they represent their 

costs in this action, including an award of reasonable 

attorneys' fees. 

 



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4. Grant such other and further equitable relief as 

the Court may deem just and proper. 

CRAWFORD, BLACKSHER & KENNEDY 

1407 DAVIS AVENUE 
MOBILE, ALABAMA 36603 

By: 0s A 5b o froze 
gx I BLACKSHER 
  

EDWARD STILL, ESQ. 
321 Frank Nelson Building 
Birmingham, Alabama 35203 

Attorneys for Plaintiffs