Complaint with cover letter to Charles Williams from James Blacksher
Correspondence
December 9, 1975

6 pages
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Case Files, Bolden v. Mobile Hardbacks and Appendices. Complaint with cover letter to Charles Williams from James Blacksher, 1975. 2d7f6a7a-cdcd-ef11-b8e8-7c1e520b5bae. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/2c4919dd-668c-47d6-a202-5e75fdafc45d/complaint-with-cover-letter-to-charles-williams-from-james-blacksher. Accessed April 29, 2025.
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h ®/ » 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 pnt » | 7 7, / A ra Charles hreadall) Fl. Boj [25 Mot Bord ague tf 3. 050 2660/ A A Shepp ar Ce fy MN CFaraee gt ii Dep ben © fori PF eb ge | oy C6 J2 firda p 48 grrr [15 hi FEV Motiv 3608 po ) a Aes wood fade i 10 10 YB yn Antuesp pls. © NM ¢ Obit, faker spp 2 ( @® ‘@ 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. N e Na o N o No l N o N o oF N o N N N N N o No N o N o No N S N N N S 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 C | ( # » 1s impracticable. There are questions of law and fact common to 4 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. { 0 'o 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 eo 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. 3 \ : * » 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