South Carolina v. Katzenbach

Almost immediately following the passage of the Voting Rights Act, the state of South Carolina brought suit directly in the Supreme Court, challenging the validity of the act. South Carolina sought a declaration from the Court that a 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 of the 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 Rights Act 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, the decision 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 as support for Congress' broad power to enact not only voting rights legislation, but also other civil rights legislation under the Fourteenth Amendment to the Constitution.