 Until it was overruled by "Baker", "Colegrove" made it almost impossible for citizens' groups to get help from the federal courts in apportioning legislative and congressional districts.An exception to the reach of "Colegrove" was allowed in a 1960 case called "Gomillion v. Lightfoot", in which the appellants showed that the boundary lines of a district in Alabama had deliberately been drawn to minimize the voting rights of black residents.Frankfurter wrote the opinion in this case as well, making sure that "Colegrove" would not be seen as allowing blatant racial gerrymandering by recasting the issue as a Fifteenth Amendment case.