Lassiter v. Northampton
360 U.S. 45 (1959)
Constitutional Topic Areas:
14th Amendment ‘Equal Protection Clause’, 14th Amendment, 15th Amendment, 17th Amendment
Case Facts:
Even after cases such as Smith v Allwright which made it unconstitutional for states to condone voter discrimination, states still attempted other methods of disenfranchising non-white voters. For decades, literacy tests were implemented as a means to discourage non-whites from voting in elections. Literacy tests generally were ambiguous, almost impossible tests in which a person must pass to gain access to the ballot box. In 1959, Lassiter, a black voter, was denied voting rights upon refusing the literacy test. Lassiter filed suit against the Northhampton County Board of Elections claiming the literacy tests violated her 14th amendment protected rights. The North Carolina District Court disagreed her 14th, 15th, and 17th amendment rights had been violated by the restrictions and Lassiter appealed to the North Carolina Supreme Court which again upheld the literacy tests. Lassiter then filed a new suit against Appellee County Board of Elections claiming literacy tests were in violation of her 14th, 15th, and 17th amendment rights.
Questions:
1. Is North Carolina’s requirement that a voter be able to read and write in English constitutional?
Holding:
1. Yes
Legal Reasoning: Justice W.O. Douglas (9-0)
1. Literacy tests insure all voting to be intelligent and all voters are proficient in the english language
2. States may require voters to pass a literacy test as long as they apply the tests equally to all and must not be used to discriminate
3. Literacy tests do not appear to be solely for discrimination and did not violate any congressionally imposed legislation protecting suffrage
Significance:
Upheld the practice of states imposing literacy tests on persons attempting to register to vote. Although the court believed this practice was constitutional on its face, the practice was inherently discriminatory as typically white registrars would administer these literacy tests to typically non-white voters and did not apply them equally to everyone as the Supreme Court had suggested
Reflection:
Lassiter would ultimately be voided by the Voting Rights Act of 1965 when Congress outlawed the practice of administering literacy tests because they were inherently discriminatory in practice. Overall, Lassiter weakened the power of the federal government
Supreme Court Case Briefs 