Katzenbach v. Morgan facts for kids
Quick facts for kids 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 | Judgment for plaintiffs, Morgan v. Katzenbach, 247 F. Supp. 196 (D.D.C. 1966) |
| 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 was an important decision by the Supreme Court of the United States in 1966. This case was about how much power the United States Congress has. Specifically, it looked at Congress's power to make laws that protect and explain parts of the 14th Amendment to the U.S. Constitution. The Court decided that Congress could make laws to expand the rights of citizens, even beyond what courts had already said.
Contents
Why the Case Happened
Before the 1960s, many places in the United States used "literacy tests." These were tests to see if people could read or write. If you couldn't pass, you couldn't vote. These tests were often used to stop minority groups from voting. In 1959, the Supreme Court had said that these tests were not always against the Constitution.
The Voting Rights Act
In 1965, Congress passed a very important law called the Voting Rights Act of 1965. This law aimed to protect the voting rights of minority groups who had been unfairly stopped from voting. One part of this law, Section 4(e), was made to help the large number of Puerto Rican people living in New York City.
Section 4(e) said that if someone had finished the sixth grade in a public or private school in Puerto Rico, where the classes were not in English, they could not be stopped from voting just because they couldn't read or write English.
The Lawsuit Begins
Some voters in New York State did not agree with this new law. They filed a lawsuit, saying that Congress had gone too far. They argued that Congress had used more power than the 14th Amendment allowed. They also said that Congress was interfering with rights that belonged to the states, as protected by the 10th Amendment.
The Supreme Court's Decision
The Supreme Court heard the case and made a decision. By a vote of 7 to 2, the Court sided with Attorney General Nicholas Katzenbach. They said that Section 4(e) of the Voting Rights Act was constitutional.
Justice Brennan's View
Justice Brennan wrote the main opinion for the majority of the Court. He explained that Section 5 of the 14th Amendment gives Congress the power to decide what laws are needed to protect the rights in that amendment. He said Congress could use its own judgment to make these laws.
Justice Brennan introduced an idea often called the "ratchet theory." This theory suggested that Congress could "ratchet up" or increase civil rights beyond what the Supreme Court had already recognized. However, Congress could not "ratchet down" or decrease rights that the courts had already protected. This meant that Congress could expand rights, setting a higher standard for protection. It also suggested that Congress could help interpret the 14th Amendment, not just the courts.
Justice Harlan's Disagreement
Justice Harlan disagreed with the majority. He wrote a dissenting opinion, criticizing the "ratchet theory." He believed that only the courts should interpret the 14th Amendment. He argued that allowing Congress to interpret the amendment would weaken the power of the courts. Justice Harlan felt that Congress's power under Section 5 should only be used to enforce rights that the courts had already recognized, not to create new ones.
What This Case Meant
Katzenbach v. Morgan was a very important case because it showed that the Supreme Court trusted Congress a lot. It gave Congress a lot of freedom to use its power under Section 5 of the 14th Amendment. This allowed Congress to pass laws that greatly expanded civil rights.
Many years later, in 1997, the Supreme Court looked at the "ratchet theory" again in the case of City of Boerne v. Flores. In that case, the Court said that the "ratchet theory" might not be the best way to understand Congress's power. This later decision addressed some of the concerns Justice Harlan had raised about the separation of powers.
