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Guinn v. United States
|Guinn v. United States|
Supreme Court of the United States
| Argued October 17, 1913|
Decided June 21, 1915
|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 Fifteenth Amendment to the United States Constitution.|
|U.S. Const. amend. XV|
Guinn v. United States, 238 U.S. 347 (1915) was an important United States Supreme Court decision that dealt with Jim Crow laws, which helped enforce segregation in the United States between 1865 and 1964. The Oklahoma statute in question, while appearing to treat white and black voters equally, allowed an exemption to the literacy requirement for those voters whose ancestors had either been eligible to vote prior to January 1, 1866 or a resident of "some foreign nation"—an exemption that favored illiterate white voters while continuing to disenfranchise illiterate black voters.
At the time of the admission of Oklahoma into the Union, in 1907, that state adopted a constitution which allowed blacks to vote, in compliance with the Fifteenth Amendment to the United States Constitution. However, an amendment to the Constitution soon followed, requiring voters to be literate; a loophole in the amendment allowed illiterates to vote if they could prove either that their grandfathers had been voters or had been citizens of some foreign nation. 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.
The Oklahoma amendment provided:
- "No person shall be registered as an elector of this state or be allowed to vote in any election held herein, unless he be able to read and write any section of the Constitution of the state of Oklahoma; but no person who was, on January 1st, 1866, or any time prior thereto, entitled to vote under any form of government, or who at that time resided in some foreign nation, and no lineal descendant of such person, shall be denied the right to register and vote because of his inability to so read and write sections of such Constitution. Precinct election inspectors having in charge the registration of electors shall enforce the provisions of this section at the time of registration, provided registration be required. Should registration be dispensed with, the provisions of this section shall be enforced by the precinct election officers when electors apply for ballots to vote."
The amendment came into force before the election of November 8, 1910 was held. During that election, certain election officers refused to allow black citizens to vote; those officers were indicted and convicted of fraudulently disenfranchishing black voters, in violation of the 15th Amendment and in violation of Oklahoma State Law.
In its decision handed down on June 21, 1915, the Court ruled that an Oklahoma law that provided an exemption that served no discernible purpose other than to favor white voters at the expense of African-American citizens' right to vote was unconstitutional.
The decision had little short-term effect, as Oklahoma immediately passed a statute that provided that all persons, except those who voted in 1914, who were qualified to vote in 1916 but who failed to register between April 30 and May 11, 1916, with some exceptions for sick and absent persons who were given an additional brief period to register, would be perpetually disenfranchised. That statute, allowing African-Americans twelve days in which to register or avoid permanent disenfranchisement, while exempting the white beneficiaries of the unlawful "grandfather" clause, was declared unconstitutional twenty-three years later in Lane v. Wilson, .
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