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Williams v. Mississippi
Seal of the United States Supreme Court.svg
Argued March 18, 1898
Decided April 25, 1898
Full case name Henry Williams v. the State of Mississippi
Citations 170 U.S. 213 (more)
18 S. Ct. 583; 42 L. Ed. 1012; 1898 U.S. LEXIS 1540
Holding
There is no discrimination in the state's requirements for voters to pass a literacy test and pay poll taxes, as these were applied to all voters.
Court membership
Case opinions
Majority McKenna, joined by unanimous
Superseded by
Voting Rights Act (1965), 42 U.S.C. §§ 19731973aa-6

Williams v. Mississippi, 170 U.S. 213 (1898), was an important case decided by the Supreme Court of the United States. It looked at the voting rules in Mississippi's 1890 constitution. These rules included things like a poll tax (a fee to vote) and literacy tests (tests to see if you could read and write). They also had a "grandfather clause" and said only registered voters could be on juries.

Henry Williams, who brought the case, argued that Mississippi's voting laws were designed to stop African Americans from voting. He said this went against the Fourteenth Amendment, which promises equal protection under the law. The Supreme Court decided that the laws themselves did not discriminate. They said that any unfair treatment came from the people who enforced the laws, not from the laws' wording.

Mississippi's Voting Rules

The 1890 constitution in Mississippi had several rules that made it hard for many people to vote. These included a poll tax, literacy tests, and a "grandfather clause." People also had to be registered voters to serve on a jury.

The poll tax and literacy tests especially affected African Americans. At that time, many African Americans had less money and fewer chances for education. This was due to a lack of resources. The grandfather clause allowed some white voters to avoid the literacy test. If their grandfather had voted before 1866, they could register automatically. This rule did not help Black Americans. Most Black grandfathers had not been allowed to vote before 1870. That was when the Fifteenth Amendment gave Black men the right to vote.

Because it was so hard for African Americans to vote, most jury members were white. The Mississippi constitution itself was approved by a group of 134 people. All but one of them were white. This group also decided to make the constitution law right away. They did not let the state's voters approve it first.

The Trial Begins

In 1896, Henry Williams was accused of a serious crime in Washington County, Mississippi. He was found guilty by an all-white jury. Williams argued that the way the jury was chosen was unfair. He said that the jury should have included people from his race. He felt he was not given equal protection under the law.

Williams asked the court to cancel the charges against him. He claimed the jury was chosen using Mississippi's unfair voting laws. He said these laws violated the Fourteenth Amendment. But the court said no. They ruled that the law itself was written so it could apply to everyone. Williams then tried to move his case to a federal court, but this was also denied. He also asked for a new trial, which was not granted.

Appeals to Higher Courts

Williams then appealed his case to the Mississippi Supreme Court. He made the same argument: that the jury that found him guilty was chosen under unfair laws. However, the Mississippi Supreme Court agreed with the lower court. They said the laws themselves were not discriminatory.

After this, Williams took his case to the U.S. Supreme Court. The Supreme Court agreed to hear his case in 1898. Williams argued that the voting laws in Mississippi's 1890 constitution went against the Fourteenth Amendment.

The Supreme Court's Decision

The U.S. Supreme Court made a unanimous decision, voting 9-0 against Henry Williams. They ruled that Williams had not shown that Mississippi's voting rules were used in a discriminatory way. Justice Joseph McKenna wrote the court's opinion. He stated that Mississippi's constitution and laws did not look unfair on paper. He also said that it was not proven that they were used in a bad way. He noted that it was only "possible" for them to be used unfairly.

This decision was made even though the state admitted that the rules had been used with the goal of discrimination. The court's main point was that the laws themselves could apply to anyone. So, they were technically not discriminatory. Any unfair targeting of African Americans was because of bias in the people enforcing the laws. The laws just gave these officers the choice to discriminate. The court said this was not a violation of the Fourteenth Amendment.

What Happened Next

After this decision, other southern states created new constitutions. These often included rules similar to Mississippi's. This happened until about 1908. These new rules made it very hard for hundreds of thousands of Black Americans to vote. They also affected tens of thousands of poor white people for many decades.

Some politicians in the northern states suggested reducing the number of seats southern states had in the House of Representatives. This would reflect how many African Americans were stopped from voting. But no action was taken. White Southern Democrats had a lot of power in Congress. They used this power for many years. For example, they blocked any federal laws against lynching.

Later, in 1915, the Supreme Court partly changed its mind. In the case Guinn v. United States, the court said that using grandfather clauses to help white people avoid literacy tests was unconstitutional. These tests were used to stop Black people from voting.

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