Minor v. Happersett
| Minor v. Happersett | |
|---|---|
|
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| Argued February 9, 1875 Decided March 29, 1875 |
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| Full case name | Virginia Minor v. Reese Happersett |
| Citations | 88 U.S. 162 (more)
22 L. Ed. 627; 21 Wall. 162
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| Prior history | Appeal from the Supreme Court of Missouri; 53 Mo. 58 (1873) |
| Holding | |
| The Fourteenth Amendment does not guarantee women the right to vote. | |
| Court membership | |
| Case opinions | |
| Majority | Waite, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XIV | |
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Superseded by
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| U.S. Const. amend. XIX (in part) | |
Minor v. Happersett, 88 U.S. 162 (1875), is a United States Supreme Court case in which the Court held that the Constitution did not grant women the right to vote. The Supreme Court upheld state court decisions in Missouri, which had refused to register a woman as a lawful voter because that state's laws allowed only men to vote.
The Minor v. Happersett ruling was based on an interpretation of the Privileges or Immunities Clause of the Fourteenth Amendment. The Supreme Court readily accepted that Minor was a citizen of the United States, but it held that the constitutionally protected privileges of citizenship did not include the right to vote.
The Nineteenth Amendment, which became a part of the Constitution in 1920, effectively overruled Minor v. Happersett by prohibiting discrimination in voting rights based on gender.Minor v. Happersett continued to be cited in support of restrictive election laws of other types until the 1960s, when the Supreme Court started interpreting the Fourteenth Amendment's Equal Protection Clause to guarantee voting rights.
Virginia Minor, a leader of the women's suffrage movement in Missouri, attempted to register to vote on October 15, 1872, in St. Louis County, Missouri, but was refused on the grounds that she was a woman. With the assistance of her husband, Francis Minor (a lawyer), she brought an action in state courts against Reese Happersett, the registrar who had rejected her application to register to vote, alleging that the provisions of the Missouri state constitution which allowed only men to vote were in violation of the United States Constitution, and specifically the Fourteenth Amendment. The key to the Minors' argument was that citizenship entailed voting rights—an assertion with enough rhetoric on both sides to make it an open question.
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