Lane v. Wilson
Headline: Oklahoma voting rule struck down as discriminatory; Court reverses and blocks a registration law that kept Black citizens off the rolls by favoring those who voted under an invalid 1914 scheme.
Holding: The Court held that Oklahoma’s 1916 registration law, by preserving voting privileges for those who voted under the struck-down 1914 'grandfather' system while imposing a narrow registration window on Black citizens, violated the Fifteenth Amendment.
- Strikes down Oklahoma’s 1916 registration law that perpetuated racial voting discrimination.
- Allows damages suits under the federal law enforcing voting rights.
- Remands the case to the lower court for further proceedings.
Summary
Background
A Black citizen sued three county election officials under a federal law that allows damages for racial discrimination in voting. He sought $5,000 after being refused registration on October 17, 1934. He had been qualified to register in 1916 but was not put on the rolls then. Oklahoma’s earlier 1914 “grandfather” provision had been declared invalid, and a 1916 law gave automatic registration to people who had voted in 1914 while requiring others to register in a short window in 1916 or be permanently disqualified.
Reasoning
The Court asked whether the 1916 registration scheme unlawfully continued racial discrimination in voting. It concluded that §5654 of the Oklahoma law impermissibly preserved the advantages of the invalid 1914 system by exempting those who had voted before the 1914 clause was struck down and imposing a very narrow registration period on others. The Court rejected defenses that the plaintiff had to use state procedures first or that earlier cases like Giles v. Harris barred his federal damages claim, and held that he could sue under the federal statute enforcing the Fifteenth Amendment.
Real world impact
The Court reversed the lower courts and found the 1916 registration rules invalid because they operated unfairly against Black citizens. The case was sent back to the district court for further proceedings consistent with this ruling. The decision removes a state rule that effectively froze racial advantages from a previously invalid system and affirms that federal damages claims can be used to challenge such discrimination.
Dissents or concurrances
Two Justices would have affirmed the lower court’s ruling and denied relief; one Justice did not participate in the case.
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