Katzenbach v. Morgan

The Morgan ruling found that the Voting Rights Act of 1965 properly extended equal protection guarantees to Puerto Ricans in New York. Precedence created by the ruling was seen as limited to situations where Congress remedied state actions denying equal protection. Section 5 of the Fourteenth Amendment was recognized as a positive grant of legislative power to Congress to determine when legislation is needed to secure the guarantees of the Fourteenth Amendment. The power is not absolute though. Congressional acts must demonstrate some reasonable possibility of addressing a legitimate equal protection concern. In Morgan, the Court found that Voting Rights Act of 1965 enabled the Puerto Rican minority to attain greater social equality and equal protection of the laws.

The decision combated a restrictive view of congressional powers in the Fourteenth Amendment as advocated by some, and added further strength to the 1965 act in fighting racial discrimination. The decision played a role in formulating the 1968 Civil Rights Act. Congress relied on the Morgan decision in expanding federal powers to prohibit racially motivated violence in hate crimes, and to outlaw private housing discrimination.

Actions of the 1960s led to more revisions later in voters' rights. The Twenty-sixth Amendment to the Constitution, ratified in 1971, lowered the voting age to 18. The Voting Rights Act was amended and strengthened in 1970, 1975, and 1982. These later revisions added use of bilingual ballots in some areas, prohibited literacy requirements, and allowed illiterate, blind, or disabled voters to be assisted in the voting booth. The 1975 amendment allowed citizens living abroad to vote in federal elections through absentee ballot. In 1984, accessibility to the voting booth for the elderly was guaranteed. Several states challenged congressional legislation lowering the voting age in all elections to 18, and establishing residency and absentee voting requirements for presidential elections.