Plaintiff
State of South Carolina
Defendant
Nicholas B. Katzenbach, U.S. Attorney General
Plaintiff's Claim
That certain portions of the Voting Rights Act of 1965 relating to eligibility tests for voters, voter qualifications, and appointment of federal voting examiners, are invalid.
Chief Lawyers for Plaintiff
David W. Robinson II, Daniel R. McLeod
Chief Defense Lawyer
Nicholas B. Katzenbach, U.S. Attorney General
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Abe Fortas, John Marshall Harlan II, Potter Stewart, Earl Warren (writingfor the Court), Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
7 March 1966
Decision
That the challenged provisions of the Voting Rights Act were consistent withthe power of Congress to eliminate racial discrimination in voting under theFifteenth Amendment to the Constitution.
Significance
Decided at the height of the civil rights movement, the Court's decision madeit clear that Congress has broad power to enact legislation to dismantle state-created barriers to voting by minorities, and was part of a series of decisions recognizing the power of the national government to enact measures against both public and private discrimination.
Following the Civil War, Congress and the state legislatures adopted three amendments to the Constitution to ensure the full benefits of citizenship to the newly freed slaves. Among these amendments was the Fifteenth Amendment, which provides that "[t]he right of citizens of the United States to vote shallnot be denied or abridged by the United States or by any State on account ofrace, color, or previous condition of servitude." The amendment also grants Congress the power to pass legislation to ensure that all citizens enjoy equally the right to vote.
Congress Passes the Voting Rights Act
Despite the Fifteenth Amendment, state and local officials had effectively denied African Americans the right to vote by imposing literacy requirements and other tests that impeded African Americans from registering to vote. For example, at the time of the 1964 presidential election, there were almost threemillion African American adults who were not registered to vote in the eleven southern states of Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia. This ledcivil rights leaders, President Lyndon Johnson, and members of both political parties in Congress to call for sweeping legislation to ensure that AfricanAmericans would have equal opportunities to participate in elections. In August 1965, the Voting Rights Act was passed by Congress and signed into law byPresident Johnson.
Although the act contained numerous provisions, three sections were principally designed to ensure that state and local governments could not erect barriers to registration of, and voting by, African Americans. These sections applied to any state or county where less than 50 percent of African Americans areregistered to vote and where literacy or other educational tests are required for registration. Section 4 suspended all such tests. Section 5 required any state or county seeking to impose a new test or registration requirement toobtain the approval of the attorney general of the United States, or of theU.S. District Court. Section 6 of the Voting Rights Act allowed the attorneygeneral to send federal examiners into the states and counties to register voters outside of the state or local system.
South Carolina Challenges Voting Rights Act
Almost immediately following the passage of the Voting Rights Act, the stateof South Carolina brought suit directly in the Supreme Court, challenging thevalidity of the act. South Carolina sought a declaration from the Court thata number of provisions of the act, particularly section 4 and section 5, were invalid. South Carolina also sought an injunction to prevent Attorney General Nicholas Katzenbach from enforcing the act. Five states filed briefs in support of South Carolina, and 21 states filed briefs in support of the Attorney General.
In perhaps one of the most significant civil rights decision made by the Court, the Court rejected South Carolina's argument that Congress had exceeded its authority under the Fifteenth Amendment by passing sections 4, 5, and 6 ofthe act. The Court held that, in exercising its power to enforce the Fifteenth Amendment, Congress may enact any law which is reasonably related to ensuring equal voting rights to all citizens. Chief Justice Warren, writing the opinion of the Court, concluded:
The Court's decision had profound direct and indirect impacts. Directly, thedecision allowed the act to go into effect and eliminate barriers to voting.For example, in the 11 southern states noted above, the number of African Americans registered to vote increased by over 800,000 between 1964 and 1967. Indirectly, the Court's decision would be relied on in numerous other cases assupport for Congress' broad power to enact not only voting rights legislation, but also other civil rights legislation under the Fourteenth Amendment to the Constitution.
Related Cases
Voting Rights Act of 1965
Passed by Congress in 1965, the Voting Rights Act gave black voters additional guarantees against discriminatory practices. The Fifteenth Amendment of 1870 prohibited the denial of any citizens' right to vote because of " . . . race, color, or previous condition of servitude." The Twenty-fourth Amendment of1964, prohibited the requirement of a poll tax or any other tax to vote in afederal election.
In spite of these two constitutional amendments, by the 1964 presidential election it became apparent that black voters continued having difficulties in some areas when attempting to register to vote. Martin Luther King, Jr. brought this issue to the forefront of American awareness after he orchestrated a march from Selma to Montgomery, Alabama. President Lyndon B. Johnson quickly authored the Voting Rights Act, which Congress ratified.
In addition to the prohibition of discrimination against blacks, the Voting Rights Act also gives the U.S. attorney general the power to send federal registrars into problem areas. These registrars are authorized to register blackvoters, ensure that they are allowed to vote, and make sure their votes are properly tallied. The act was readopted in 1970, 1975, 1985, and can be extended by Congress.
Sources
Grilliot, Harold J., and Frank A. Schubert. Introduction to Law and the Legal System. Boston, MA: Houghton Mifflin Co., 1992.
"Voting Rights Act Clarification," http://www.usdoj.gov/crt/voting/clarify3.htm.
State of South Carolina
Defendant
Nicholas B. Katzenbach, U.S. Attorney General
Plaintiff's Claim
That certain portions of the Voting Rights Act of 1965 relating to eligibility tests for voters, voter qualifications, and appointment of federal voting examiners, are invalid.
Chief Lawyers for Plaintiff
David W. Robinson II, Daniel R. McLeod
Chief Defense Lawyer
Nicholas B. Katzenbach, U.S. Attorney General
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Abe Fortas, John Marshall Harlan II, Potter Stewart, Earl Warren (writingfor the Court), Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
7 March 1966
Decision
That the challenged provisions of the Voting Rights Act were consistent withthe power of Congress to eliminate racial discrimination in voting under theFifteenth Amendment to the Constitution.
Significance
Decided at the height of the civil rights movement, the Court's decision madeit clear that Congress has broad power to enact legislation to dismantle state-created barriers to voting by minorities, and was part of a series of decisions recognizing the power of the national government to enact measures against both public and private discrimination.
Following the Civil War, Congress and the state legislatures adopted three amendments to the Constitution to ensure the full benefits of citizenship to the newly freed slaves. Among these amendments was the Fifteenth Amendment, which provides that "[t]he right of citizens of the United States to vote shallnot be denied or abridged by the United States or by any State on account ofrace, color, or previous condition of servitude." The amendment also grants Congress the power to pass legislation to ensure that all citizens enjoy equally the right to vote.
Congress Passes the Voting Rights Act
Despite the Fifteenth Amendment, state and local officials had effectively denied African Americans the right to vote by imposing literacy requirements and other tests that impeded African Americans from registering to vote. For example, at the time of the 1964 presidential election, there were almost threemillion African American adults who were not registered to vote in the eleven southern states of Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia. This ledcivil rights leaders, President Lyndon Johnson, and members of both political parties in Congress to call for sweeping legislation to ensure that AfricanAmericans would have equal opportunities to participate in elections. In August 1965, the Voting Rights Act was passed by Congress and signed into law byPresident Johnson.
Although the act contained numerous provisions, three sections were principally designed to ensure that state and local governments could not erect barriers to registration of, and voting by, African Americans. These sections applied to any state or county where less than 50 percent of African Americans areregistered to vote and where literacy or other educational tests are required for registration. Section 4 suspended all such tests. Section 5 required any state or county seeking to impose a new test or registration requirement toobtain the approval of the attorney general of the United States, or of theU.S. District Court. Section 6 of the Voting Rights Act allowed the attorneygeneral to send federal examiners into the states and counties to register voters outside of the state or local system.
South Carolina Challenges Voting Rights Act
Almost immediately following the passage of the Voting Rights Act, the stateof South Carolina brought suit directly in the Supreme Court, challenging thevalidity of the act. South Carolina sought a declaration from the Court thata number of provisions of the act, particularly section 4 and section 5, were invalid. South Carolina also sought an injunction to prevent Attorney General Nicholas Katzenbach from enforcing the act. Five states filed briefs in support of South Carolina, and 21 states filed briefs in support of the Attorney General.
In perhaps one of the most significant civil rights decision made by the Court, the Court rejected South Carolina's argument that Congress had exceeded its authority under the Fifteenth Amendment by passing sections 4, 5, and 6 ofthe act. The Court held that, in exercising its power to enforce the Fifteenth Amendment, Congress may enact any law which is reasonably related to ensuring equal voting rights to all citizens. Chief Justice Warren, writing the opinion of the Court, concluded:
After enduring nearly a century of widespread resistance to the Fifteenth Amendment, Congress has marshalled an array of potent weapons against the evil, with authority in the Attorney General to employ them effectively. Many of the areas directly affected by this development have indicated their willingness to abide by any restraints legitimately imposed upon them. We here hold that the portions of the Voting RightsAct properly before us are valid means for carrying out the commands of the Fifteenth Amendment. Hopefully, millions of non-white Americans will now be able to participate for the first time on an equal basis in the government under which they live.
The Court's decision had profound direct and indirect impacts. Directly, thedecision allowed the act to go into effect and eliminate barriers to voting.For example, in the 11 southern states noted above, the number of African Americans registered to vote increased by over 800,000 between 1964 and 1967. Indirectly, the Court's decision would be relied on in numerous other cases assupport for Congress' broad power to enact not only voting rights legislation, but also other civil rights legislation under the Fourteenth Amendment to the Constitution.
Related Cases
- Ex parte Garland, 71 U.S. 333 (1866).
- Coyle v. Smith, 221 U.S. 559 (1911).
- Guinn v. United States, 238 U.S. 347 (1915).
- Mulford v. Smith, 307 U.S. 38 (1939).
- United States v. Darby, 312 U.S. 100 (1941).
- Gomillion v. Lightfoot, 364 U.S. 339 (1960).
- Heart of Atlanta Motel v. United States, 379 U.S. 241 (1964).
- Katzenbach v. McClung, 379 U.S. 294 (1964).
Voting Rights Act of 1965
Passed by Congress in 1965, the Voting Rights Act gave black voters additional guarantees against discriminatory practices. The Fifteenth Amendment of 1870 prohibited the denial of any citizens' right to vote because of " . . . race, color, or previous condition of servitude." The Twenty-fourth Amendment of1964, prohibited the requirement of a poll tax or any other tax to vote in afederal election.
In spite of these two constitutional amendments, by the 1964 presidential election it became apparent that black voters continued having difficulties in some areas when attempting to register to vote. Martin Luther King, Jr. brought this issue to the forefront of American awareness after he orchestrated a march from Selma to Montgomery, Alabama. President Lyndon B. Johnson quickly authored the Voting Rights Act, which Congress ratified.
In addition to the prohibition of discrimination against blacks, the Voting Rights Act also gives the U.S. attorney general the power to send federal registrars into problem areas. These registrars are authorized to register blackvoters, ensure that they are allowed to vote, and make sure their votes are properly tallied. The act was readopted in 1970, 1975, 1985, and can be extended by Congress.
Sources
Grilliot, Harold J., and Frank A. Schubert. Introduction to Law and the Legal System. Boston, MA: Houghton Mifflin Co., 1992.
"Voting Rights Act Clarification," http://www.usdoj.gov/crt/voting/clarify3.htm.
User Comments Add a comment…