Guinn v. United States facts for kids
Quick facts for kids 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 was a very important case decided by the U.S. Supreme Court in 1915. It said that certain rules, called "grandfather clauses," which were used with literacy tests for voting, were against the law. These clauses seemed fair on the surface. However, they were actually made to let white voters who couldn't read or write still vote. At the same time, they stopped most African Americans from voting, even if they could read.
The 15th Amendment was passed in 1870. It made it illegal for any state to stop people from voting because of their race, color, or if they had been enslaved. After this, many Southern states, like Oklahoma, created new rules. These rules were designed to stop African Americans from voting without directly breaking the 15th Amendment. Chief Justice Edward Douglass White wrote the main opinion for the Court. He said that Oklahoma's grandfather clause was "against the 15th Amendment and therefore invalid." Sadly, this decision didn't immediately change much. Southern states quickly found other ways to stop black citizens from voting.
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Voting Rules in Oklahoma
When Oklahoma became a state in 1907, its first constitution allowed all men to vote. This followed the rules of the Fifteenth Amendment to the United States Constitution. But soon after, lawmakers in Oklahoma added a change to the state's constitution. This new rule said that voters had to pass a literacy test. This meant they had to prove they could read and write.
However, there was a special part of this rule, called a "grandfather clause." It said you didn't have to pass the literacy test if your grandfathers had been voters or citizens of another country, or if they had served as soldiers before 1866. This loophole meant that white people who couldn't read could still vote. But most African Americans couldn't use this rule. Their grandfathers had almost all been enslaved. This meant they couldn't vote or be soldiers before 1866.
Even if some black families had been free before the Civil War, they often couldn't get this exemption either. This was because many states had taken away voting rights from free black people before 1840. In real life, white officials gave these tests. They often used them unfairly to stop black voters. Many Southern states had similar grandfather clauses in their laws.
The Oklahoma amendment stated:
- "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 1, 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."
This new rule started before the election in November 1910. During that election, some election workers stopped black citizens from voting. These workers were later charged and found guilty of unfairly stopping black voters. This was against the 15th Amendment and Oklahoma state law.
The Fifteenth Amendment's Role
The 15th Amendment is a very important part of the U.S. Constitution. It says that no one can be stopped from voting because of their race, color, or if they were once enslaved. Some people thought the Grandfather Clause in Oklahoma's Constitution didn't break this rule. They argued it looked at relatives from before 1866, not 1871, which they claimed created a loophole.
How Grandfather Clauses Started
Grandfather clauses were first created to let white people vote while stopping black people from voting. The clause in the Guinn v. United States case involved needing to pass a literacy test to register to vote. At that time, many poor white people in the South couldn't read. They would lose their right to vote if they had to pass a literacy test.
Grandfather clauses were added because most poor white people had grandfathers who could vote. These clauses usually allowed poor white people who couldn't read to register if they or their ancestors could have voted before 1867. This created a special way for them to vote. These laws often had time limits. This was to get as many white voters registered as possible before the laws were challenged in court.
The Supreme Court Case
The Guinn v. United States case was argued before the Supreme Court on October 17, 1913. This was the second time John W. Davis appeared before the Court as the U.S. Solicitor General. It was also the first case where the National Association for the Advancement of Colored People (NAACP) officially presented their views to the Court.
After hearing the arguments, the Supreme Court decided that Oklahoma's Grandfather Clause was made to keep as many illiterate black people as possible from voting. It also aimed to let as many illiterate white people as possible vote. The number of black citizens allowed to vote was about the same as the number of white citizens stopped from voting. This showed clear discrimination. The Court ruled that the entire amendment about literacy for voters was against the Constitution. It violated the 15th Amendment. The clause was an attempt to avoid breaking the 15th Amendment directly while still stopping black voters. The past conditions of slavery often meant black people couldn't get an education. This made it impossible for them to meet the unfair rules in the clause. The convictions of Guinn and Beal, the election officers, were upheld.
The Court's Decision
The Supreme Court announced its decision in Guinn v. United States on June 21, 1915. They also decided a similar case, Myers v. Anderson, about a grandfather clause in Maryland. The Court found that "the grandfather clauses in the Maryland and Oklahoma constitutions were against the Fifteenth Amendment and therefore invalid." Chief Justice Edward Douglass White wrote the main opinion. He said that the grandfather clause was clearly made to get around the voting rights protected by the 15th Amendment. This was true even though the clause didn't mention race directly.
What Happened Next
Even though Guinn v. United States seemed like a big win for black voters, it didn't immediately change things much. Oklahoma quickly put a new voting law in place. This law made it harder to register to vote. It said that almost everyone who voted in 1914, and was qualified to vote in 1916, but didn't register between April 30 and May 11, 1916, would lose their right to vote forever. There were only a few exceptions for sick or absent people.
After the Guinn decision, similar clauses in other Southern states like Alabama, Georgia, Louisiana, North Carolina, and Virginia were also struck down. But just like Oklahoma, these states found other ways to stop black voters. They mainly used poll taxes. Many states also kept literacy tests. Only the use of Grandfather Clauses was stopped. This meant that poor white people, as well as black people, were still stopped from voting.
Twenty-three years later, the Supreme Court struck down Oklahoma's new voting law in the case of Lane v. Wilson. The Court ruled that the new law still broke the 15th Amendment. It said the law "operated unfairly against the very class on whose behalf the protection of the Constitution was here successfully invoked." Guinn was important because it opened the door for courts to step in when voting rights were being unfairly taken away. However, it did not immediately give black voters in the South the right to vote, as many had hoped.
