South Carolina v. Katzenbach

Following is the case brief for South Carolina v. Katzenbach, 383 U.S. 301 (1966)

Case Summary of South Carolina v. Katzenbach:

  • The State of South Carolina filed a bill of complaint directly to the Supreme Court.
  • The State challenged a number of provisions of the Voting Rights Act of 1965, including a ban on literacy tests, a federal right to approve State voting law changes, and a federal right to install voting examiners if complaints are made.
  • The U.S. Supreme Court dismissed the complaint.  The Court upheld the relevant portions of the Voting Rights Act as a proper exercise of the authority granted under the Fifteenth Amendment, which is focused on removing racial discrimination in voting.

South Carolina v. Katzenbach Case Brief

Statement of the Facts:

The State of South Carolina filed a complaint, invoking the Supreme Court’s original jurisdiction under Article III, § 2 of the Constitution and seeking a declaration that certain provisions of the Voting Rights are unconstitutional.  The State argues that the provisions exceed the authority given to Congress under the Fifteenth Amendment.

The specific provisions at issue are (i) a suspension of any voting tests (such as literacy tests); (ii) federal review of any State voting law changes before they take effect; and (iii) the ability of the federal government to have federal examiners in a State election.

Procedural History:

  • The State of South Carolina’s bill of complaint sought the Court’s original jurisdiction.
  • The U.S. Supreme Court granted leave to hear the bill of complaint.

Issue and Holding:

Does the Voting Rights Act violate the Fifteenth Amendment?  No.

Judgment:

The Bill of complaint is dismissed.

Rule of Law or Legal Principle Applied:

The Fifteenth Amendment is a valid basis under the Constitution for the Voting Rights Act of 1965.

Reasoning:

Historical context is important.  The Voting Rights Act of 1965 was passed after days of legislative hearings revealing that a number of southern States, including South Carolina, have flagrantly refused to honor the Fifteenth Amendment.  In fact, South Carolina and other States have systematically employed all types of schemes to keep African-Americans from voting.  The Voting Rights Act, therefore, is a legitimate means to combat the evil of voter suppression based on race.

South Carolina’s many arguments to try to remove itself from the purview of the Fifteenth Amendment and the Voting Rights Act, such as claiming that it is a “person” with Fifth Amendment due process rights, are without merit.  Under the Fifteenth Amendment, Congress has the authority, as against the States, to use any rational means to effectuate the constitutional prohibition of racial voting discrimination.

Concurring and Dissenting Opinions:

Concurring in part, Dissenting in part (Black):

Most of the provisions at issue are a proper exercise of authority under the Fifteenth Amendment.  However, requiring federal approval of State voting law changes, which essentially gives the federal government veto power of State law, violates the “Republican Form of Government” clause of the Constitution.

Significance:

South Carolina v. Katzenbach was a watershed moment for the Civil Rights Movement, allowing 800,000 African-Americans to register to vote between 1964 and 1967.  A more conservative Court in 2013 undermined the power of Katzenbach by striking down the Voting Rights Act because it was based on old data.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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