Katzenbach v. Morgan
| Katzenbach v. Morgan | |
|---|---|
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| Argued April 18, 1966 Decided June 13, 1966 |
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| Full case name | Nicholas Katzenbach, Attorney General, et al. v. Morgan et ux. |
| Citations | 384 U.S. 641 (more)
86 S. Ct. 1717; 16 L. Ed. 2d 828; 1966 U.S. LEXIS 1337
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| Prior history | A 3-judge panel of the United States District Court for the District of Columbia granted appellees declaratory and injunctive relief |
| Holding | |
| Congress may enact laws stemming from its 14th Amendment enforcement power that increase the rights of citizens beyond what the judiciary has recognized. | |
| Court membership | |
| Case opinions | |
| Majority | Brennan, joined by Warren, Black, Clark, White, Fortas |
| Concurrence | Douglas |
| Dissent | Harlan, joined by Stewart |
| Laws applied | |
| U.S. Const. amend. XIV; Voting Rights Act of 1965: Section 4(e) | |
Katzenbach v. Morgan, 384 U.S. 641 (1966), was a United States Supreme Court case regarding the power of Congress, pursuant to Section 5 of the 14th Amendment, to enact laws that enforce and interpret provisions of the Constitution.
Prior to the 1960s, many US states and municipalities used literacy tests to disenfranchise minorities. In 1959, the US Supreme Court held, in Lassiter v. Northampton County Board of Elections, that literacy tests were not necessarily violations of Equal Protection Clause of the 14th Amendment or the 15th Amendment.
In 1965, Congress passed the Voting Rights Act of 1965, which sought to safeguard the voting rights of disenfranchised minorities. Among other provisions, the Voting Rights Act made some literacy tests illegal. Section 4(e) was aimed at securing the franchisement of New York City's large Puerto Rican population and "provides that no person who has completed the sixth grade in a public school, or an accredited private school, in Puerto Rico in which the language of instruction was other than English shall be disfranchised for inability to read or write English."
Registered voters in the state of New York brought suit by alleging that Congress exceeded its powers of enforcement under the 14th Amendment and alleging that Congress infringed on rights reserved to states by the 10th Amendment.
By a 7-2 decision, the Supreme Court sided with Attorney General Nicholas Katzenbach, reversed the District Court, and held that Section 4(e) was constitutional. Writing the majority opinion, Justice Brennan stressed that Section 5 of the amendment is "a positive grant of legislative power authorizing Congress to exercise its discretion in determining the need for and nature of legislation to secure Fourteenth Amendment guarantees." Justice Brennan applied the appropriateness standard of McCulloch v. Maryland (1819) to determine whether the legislation passed constitutional muster.
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