United States v. Alabama

Background

The United States sued the county board of registrars in Macon County, Alabama, and two local election officials, alleging a pattern of racially discriminatory practices meant to deny Black citizens the right to vote under the Fifteenth Amendment and the Civil Rights Act of 1957. The Government originally proceeded under the 1957 law and later amended its complaint to add the State of Alabama. The District Court dismissed the case against all defendants, ruling the officials were no longer suable in office, the board was not a legal entity that could be sued, and the 1957 law did not authorize a suit against the State. The Court of Appeals affirmed that judgment.

Reasoning

While the case was pending here, Congress enacted the Civil Rights Act of 1960, which in §601(b) amended the enforcement statute to say the State can be joined as a defendant in suits alleging voting-rights deprivations. The Court therefore considered the case under the new law now controlling. It held that the 1960 amendment gives the District Court the authority to hear this suit against the State of Alabama. The Court did not decide the underlying merits of the voting-rights claims or any defenses the State might raise.

Real world impact

Because of this decision, the lower courts’ judgments are vacated and the case is sent back to the District Court with instructions to reinstate the action against the State and proceed consistent with the opinion. This ruling lets the federal government pursue claims against a State under the amended law, but it is not a final decision on whether the alleged discrimination actually occurred.