McDonald v. Board of Election Commissioners of Chicago facts for kids
Quick facts for kids McDonald v. Board of Election Commissioners of Chicago |
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| Argued November 19, 1968 Decided April 28, 1969 |
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| Full case name | 'Sam L. McDONALD and Andrew Byrd on behalf of themselves and all other persons similarly situated, v. BOARD OF ELECTION COMMISSIONERS OF CHICAGO, Sidney T. Holzman, Chairman, Marie H. Suthers, Commissioner, and Francis P. Canary, Commissioner' |
| Docket no. | 68 |
| Citations | 394 U.S. 802 (more)
89 S.Ct. 1404, 22 L.Ed.2d 739
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| Argument | Oral argument |
| Case history | |
| Prior | Summary judgment granted for defendants, 277 F.Supp. 14 (1967) |
| Holding | |
| An Illinois law that granted absentee ballots to various eligible voters but not to inmates awaiting trial did not violate the Equal Protection clause of the Fourteenth Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | Warren, joined by Black, Douglas, Brennan, White, Fortas, Marshall |
| Concurrence | Harlan and Stewart |
| Laws applied | |
| U.S Const. amend. XIV | |
McDonald v. Board of Election Commissioners of Chicago was a big decision by the Supreme Court of the United States in 1969. The Court decided that a law in Illinois was fair. This law said that people in jail who were waiting for their trial could not get absentee ballots. An absentee ballot lets you vote by mail if you can't go to the polling place in person.
The Court said this law did not go against the Fourteenth Amendment of the U.S. Constitution. This amendment includes the Equal Protection Clause, which means states must treat everyone fairly under the law. The Court decided that the state's reasons for the law were sensible. They also pointed out that the people in jail hadn't shown they couldn't vote in other ways, only that they couldn't get absentee ballots.
Contents
Why the Case Started
This case began with two people, Sam L. McDonald and Andrew Byrd. They were in jail in Cook County, Illinois, waiting for their trials. In Illinois, people who had been found guilty of crimes could not vote. But McDonald and Byrd had not been found guilty yet, so they still had the right to vote.
In March 1967, they tried to get absentee ballots. Illinois law allowed people to get absentee ballots for a few reasons:
- If they were away from their home county.
- If they were physically unable to go to the polls, with a doctor's note.
- If they had a religious holiday on election day.
- If they were working as a poll watcher in another county.
McDonald and Byrd thought their situation counted as "physical incapacity." They even got a note from the jail warden saying so. But the Board of Election Commissioners of Chicago said no. They explained that "physical incapacity" only meant medical problems, not being in jail.
The Case in Lower Court
McDonald and Byrd then sued in a federal court in Chicago. They argued that not giving them absentee ballots went against their right to vote and the Equal Protection Clause of the Fourteenth Amendment. They wanted the court to order the Board to give them ballots. The Board, however, asked the court to dismiss the lawsuit. They said giving the inmates ballots would be against Illinois law.
McDonald and Byrd argued that there was no good reason for Illinois to treat them differently. Other people who were away from their home county, even if they were in jail in another county, could get absentee ballots. They felt the state was being unfair.
On March 30, the District Court first allowed the inmates to get ballots temporarily. But after more hearings, on December 11, the court sided with the Board. The court agreed that "physical incapacity" in the law meant only medical reasons. The court also looked at other cases where similar state laws about absentee ballots were found to be fair. Because Illinois's rules seemed no more unfair than those other examples, the court ruled for the Board. McDonald and Byrd then took their case directly to the Supreme Court.
The Supreme Court's Decision
What the Majority Said
The Supreme Court agreed with the lower court's decision. All nine justices voted the same way. Chief Justice Warren wrote the main opinion for the Court. He explained that McDonald and Byrd had two main complaints:
- They said there was no good reason to treat people with medical problems differently from those in jail.
- They also said there was no good reason to treat people in jail in their home county differently from those in jail in another county.
The Court first explained why they didn't need to use a very strict way of looking at the law, called "strict scrutiny." This strict review is usually used when laws affect basic rights like voting, or when they treat people differently based on things like race or wealth.
Chief Justice Warren wrote that this strict review wasn't needed here for two reasons:
- First, the Illinois law didn't treat people differently based on their money or race.
- Second, there was no proof that the law actually stopped McDonald and Byrd from voting. It only stopped them from getting absentee ballots. The Court said that the real issue wasn't the right to vote itself, but the right to get an absentee ballot.
Instead, the Court used a less strict test. They looked to see if the law had a "rational relationship to a legitimate state end." This means they checked if the law made sense and had a good reason behind it. From this point of view, the Illinois absentee ballot laws were fine.
The Court found it made sense to offer voting help to people with medical issues without giving the same help to everyone. It also made sense for the state not to want people in jail voting for local officials from inside the prison. The Court noted that McDonald and Byrd had not tried to vote in any other way besides asking for an absentee ballot. Illinois might have allowed them to vote in a different manner.
What the Other Justices Said
Justices Harlan and Stewart agreed with the final decision. However, they did not join the main opinion written by Chief Justice Warren, nor did they write their own separate opinion.
