Lassiter v. Northampton County Board of Elections
Headline: Court upholds North Carolina’s neutral literacy test for voter registration, allowing states to require reading-and-writing tests so long as they are applied equally and not used to discriminate by race.
Holding: In a one-sentence holding, the Court affirmed the state courts and held that a neutral literacy test for voter registration does not violate the Constitution so long as it is applied equally and not used to discriminate by race.
- Permits states to use neutral literacy tests for voter registration if applied equally.
- Affirms denial of registration when applicant refuses required literacy test.
- Preserves federal review if tests are enforced in a discriminatory way.
Summary
Background
A Black North Carolina citizen applied to register to vote and refused to take the State’s literacy test. The registrar and the county Board of Elections denied her registration. State trial and appellate courts, including the North Carolina Supreme Court, upheld the literacy requirement. The State Constitution’s §4 included a literacy test and a grandfather clause; a 1957 state law reworded the statutory registration scheme and omitted the grandfather clause, and earlier federal proceedings had stayed action to let state administrative and court remedies run their course.
Reasoning
The Court addressed whether a State may require a literacy test of all voters regardless of race under the Fourteenth and Fifteenth Amendments. The opinion explained that States may set voter qualifications so long as they are not discriminatory. A test that asks an applicant to read and write a section of the State Constitution in English is a neutral way to measure literacy. The Court found no basis in the statute and record to infer that North Carolina’s literacy requirement was a calculated scheme to deny voting on racial grounds and therefore could not be struck down on its face.
Real world impact
The ruling affirms that a neutrally worded literacy test may remain in effect when applied equally, and it upholds the state courts’ denial of registration to this applicant who refused the test. The Court also made clear that if a state applies such rules in a discriminatory way in practice, that specific discrimination can be raised later in federal proceedings and challenged under the Constitution.
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