Guinn v. United States
| Guinn v. United States | |
|---|---|
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| Argued October 17, 1913 Decided June 21, 1915 |
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| Full case name | Frank Guinn and J. J. Beal v. United States |
| Citations | 238 U.S. 347 (more)
35 S. Ct. 926; 59 L. Ed. 1340; 1915 U.S. LEXIS 1572
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| Prior history | Certificate from the Circuit Court of Appeals for the Eighth Circuit |
| Holding | |
| A state statute drafted in such a way as to serve no rational purpose other than to disadvantage the right of African-American citizens to vote violated the 15th Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | White, joined by McKenna, Holmes, Day, Hughes, Van Devanter, Lamar, Pitney |
| McReynolds took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. amend. XV | |
Guinn v. United States, 238 U.S. 347 (1915), was a United States Supreme Court decision that dealt with provisions of state constitutions that set qualifications for voters. It found grandfather clause exemptions to literacy tests to be unconstitutional. The Oklahoma Constitution, while appearing to treat all voters equally, allowed an exemption to the literacy requirement for those voters whose grandfathers had either been eligible to vote prior to January 1, 1866 or were then a resident of "some foreign nation", or were soldiers. It was an exemption that favored white voters while it disfranchised black voters, most of whose grandfathers had been slaves and therefore unable to vote before 1866.
"In 1915, in the case of Guinn v. United States, the Supreme Court declared the grandfather clauses in the Maryland and Oklahoma constitutions to be repugnant to the Fifteenth Amendment and therefore null and void." This also affected similar provisions in the constitutions of Alabama, Georgia, Louisiana, North Carolina, and Virginia. While the grandfather clause was ruled unconstitutional, state legislatures worked to develop other means of restricting voter registration. It took years for cases challenging those laws to reach the Supreme Court.
When Oklahoma was admitted to the Union in 1907, it had adopted a constitution which allowed men of all races to vote, in compliance with the Fifteenth Amendment to the United States Constitution. However, legislators soon passed an amendment to the Constitution that required voters to satisfy a literacy test. A potential voter could be exempted from the literacy requirement if he could prove either that his grandfathers had been voters or had been citizens of some foreign nation, or had served as soldiers before 1866. As a result, illiterate whites were able to vote — but not illiterate blacks, whose grandfathers had almost all been slaves and therefore barred from voting or serving as soldiers before 1866. Most states that had permitted free people of color to vote in early decades of the 19th century had rescinded that right before 1840. Thus, even African Americans who might have descended from families free before the Civil War could not get an exemption from literacy tests. In practice these were highly subjective, administered by white registrars who discriminated against black voters. Oklahoma's amendment followed those of numerous Southern states that had similar grandfather clauses in their constitutions.
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