The annexation that diluted Richmond's Black vote
Annexation effective 1970; decided 24 June 1975; ward elections 1977The 23 square miles annexed from Chesterfield County, south and west of the James, Richmond City, VA
In 1970 Richmond annexed 23 square miles of Chesterfield County and 47,262 people, 1,557 of whom were Black, taking the city from 52 per cent Black to 42. The mayor had asked the county for assurances of at least 44,000 additional white citizens.
Richmond elected its city council at large, which meant that a Black majority spread across the city could be outvoted in every seat. By the end of the 1960s white flight was moving the city towards that Black majority. The annexation of 1970 moved the city instead: 23 square miles of Chesterfield County and 47,262 people, of whom 1,557 were Black. A city of 202,359 people that was 52 per cent Black became a city of 249,621 that was 42 per cent Black.
Curtis Holt sued in February 1971, and the litigation ran five and a half years. The record the courts examined left little to infer. The District Court found that the city's leadership had been motivated by a discriminatory racial purpose, that its focus in the negotiations with the county "was upon the number of new white voters it could obtain", and that the mayor had "required assurances from Chesterfield County officials that at least 44,000 additional white citizens would be obtained".
The Supreme Court decided City of Richmond v. United States on 24 June 1975. It held that an annexation which reduces the Black share of a city's population is not by itself barred by section 5 of the Voting Rights Act, provided the post-annexation electoral system fairly recognises the political strength of the Black community as it exists after the annexation - a ward plan, rather than at-large seats, could do that. But it also held that "an official action, whether an annexation or otherwise, taken for the purpose of discriminating against Negroes on account of their race has no legitimacy at all", and sent the case back on that question. The annexation itself was never undone.
What changed was how the council was elected. Richmond held no council elections from 1970 until 1977 while the litigation ran. It then went to nine wards, four of them with Black majorities above 64 per cent. The 1977 election produced the city's first majority-Black council, which chose Henry L. Marsh III as Richmond's first Black mayor - seven years, and three lawsuits, after the city had bought itself 44,000 white voters.
47,262 people were brought into the city, 1,557 of them Black, taking Richmond from 52 per cent Black to 42 per cent. No council elections were held for seven years.
Sources
- City of Richmond v. United States, 422 U.S. 358 (1975)United States Reports, Library of Congresstile.loc.govThe opinion itself: the annexation's area and population figures, the District Court's findings on the city's purpose and the mayor's demand for 44,000 white citizens, the holding on section 5 and ward plans, and the decision date.
- We Demand Complete Realization: The Slow Legal Fight for EnfranchisementThe UncommonWealth, Library of Virginiauncommonwealth.lva.virginia.govCurtis Holt's challenge, the roughly 44,000 white residents added by the annexation, the at-large council that made the dilution work, and the move to ward voting in Richmond and Petersburg.
- From Intent to Effect: Richmond, Virginia, and the Protracted Struggle for Voting Rights, 1965-1977Jepson School of Leadership Studies, University of Richmondscholarship.richmond.eduThe litigation from Holt's first suit in February 1971 to its conclusion in November 1976, the seven years without council elections, the shift to wards, and the 1977 election of a majority-Black council and Henry Marsh as mayor.