ANDERSON Et Al. v. MARTIN

1964-01-13
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Headline: Court strikes down Louisiana law requiring race to be listed on ballots, saying the labels encourage racial voting and unlawfully promote discrimination against candidates.

Holding:

Real World Impact:
  • Bars states from listing candidates' race on official ballots.
  • Reduces state-sponsored cues that encourage racially based voting.
  • Protects candidates from official actions that induce racial prejudice.
Topics: race and elections, voting rights, equal protection, ballot design

Summary

Background

A group of Black residents of East Baton Rouge ran for the local school board and sued the Louisiana Secretary of State to stop enforcement of a 1960 law that required the race of every candidate to be printed beside their name on primary and general election ballots. They sought emergency and permanent court orders; a three-judge federal court denied relief by a 2-to-1 vote, and the State defended the statute as simply informational.

Reasoning

The central question was whether forcing the State to place a racial label on each candidate’s name violates the Constitution’s protections. The Court held that the compulsory racial designation on the official ballot operates as state-sponsored discrimination and therefore violates the Fourteenth Amendment’s Equal Protection Clause. The opinion explained that by directing voters’ attention to race at the moment of voting, the State supplies a vehicle for racial prejudice, that the 1960 change added race as the only extra candidate detail, and that race has no legitimate relevance to a candidate’s qualifications.

Real world impact

The Court reversed the lower court and invalidated the Louisiana provision requiring race on ballots. As a practical matter, states may not put an official racial label beside a candidate’s name because doing so places the power of the State behind a racial classification that induces prejudice at the polls. The Court did not reach the appellants’ other constitutional claims, so those issues remain unaddressed here.

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